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HomeMy WebLinkAbout03-0774IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MURDINA ANN BELL, and CHRISTINA MARIE BELL, a minor, by her parent and guardian WANDA BELL, Plaintiffs DARYL RHEY RHINE, Defendant NO. ~3 -- 7'79' CIVIL ACTION-LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you in the following pages, you must take action within twenty (20) days afle~, 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 objectiorls to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a default judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other fights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service Two Liberty Street Carlisle, Pennsylvania 17013 (717) 249 - 3166 1-800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MURDINA ANN BELL, and CHRISTINA MARIE BELL, a minor, by her parent and guardian WANDA BELL, Plaintiffs DARYL RHEY RHINE, Defendant NO. CIVIL ACTION-LAW JURY TRIAL DEMANDED AVI~O USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea de£enderse de las quejas e×puestas en las ph~inas si~uientes, debe romar ac¢i6n dentro de veinte (20) dias a partir de la £echa en que re¢ibi6 la demanda y el aviso. Usted debe presentar ¢omparecen¢ia escrita en persona o pot abogado y presentar en la Corte pot escrito sus defensas o sus obje¢iones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede de¢idir en su contra sin mas av~so o notificaci~n pot cualquier dinero re¢lamado en la demanda o pot cualquier otra queja o ¢ompensa¢i~n reclamados pot el Demandante. USTED PUED£ PERDER DINERO, O PROPRIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service Two Liberty Street Carlisle, Pennsylvania 17013 (717) 249- 3166 1-800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MURDINA ANN BELL, and CHRISTINA MARIE BELL, a minor, by her parent and guardian WANDA BELL, Plaintiffs Ve DARYL RHEY RHINE, Defendant CIVIL ACTION-LAW JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff Murdina A. Bell is an adult individual residing at 7515 Redwood County Road, Orlando, FL 32835. 2. The Minor Plaintiff Christina Marie Bell, date of birth January, 11, 1988, resides at 7515 Redwood County Road, Orlando, FL 32835. 3. PlaintiffWanda Bell, is the parent and natural guardian of Christina Made Bell, and resides at 7515 Redwood County Road, Orlando, FL 32835 4. The Defendant is an adult individual residing at 131 Zion Road, Newburg, PA 17240. 5. On July 24, 2002, PlaintiffMurdina A. Bell was the owner and operator of a 1997 Chevrolet Cavalier bearing Florida registration plate G34DPB. 6. On July 24, 2002, Defendant was the operator of a 1989 automobile beating PA registration plate DKN-6060. 7. On July 24, 2002 at approximately 4:11 p.m., Murdina A. Bell, with Minor Plaintiff Christine Made Bell as a passenger, had backed her vehicle out of a driveway located on the east side of Jumper Road approximately 5 miles north of Shippensburg Boro, and had stopped the vehicle in the southbound lane in order to place the vehicle into forward gear. 8. At that same time and place, the Defendant was operating his vehicle southbound on Jumper Road at a high rate of speed when he failed to stop before striking the rear of Plaintiff s vehicle resulting in injuries and damages to the Plaintiffs. 9. This accident occurred as a result of the negligence of the Defendant and was due in no manner to any act, or failure to act, on the part of the Plaintiff. 10. This matter is alleged to exceed the applicable limits of arbitration, and a jury trial is hereby demanded. 11. The negligence of the Defendant consisted of the following. a) Failing to properly operate and control his motor vehicle; b) Failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; c) Operating his vehicle in careless disregard for the safety of others and the Plaintiffs in particular in violation of 75 Pa.C.S. §3714; d) Operating his vehicle too fast for the conditions then and there existing in violation of 75 Pa. C.S. §3361; e) Failing to stop within the assured clear distance ahead in violation of 75 Pa. C.S. §3361; and f) Failing to observe the presence of Plaintiffs vehicle when the Defendant knew or should have known of the presence of Plaintiff's vehicle. COUNT 1 MURDINA A. BELL V. DARYL RHEY RHINE 12. Thc allegations contained in paragraphs 1 through 11, inclusive, are incorporated herein as fully as though set forth at length. 13. As a result of the negligence of the Defendant, the Plaintiff suffered serious and permanent injuries including but not limited to low back injuries and a severe shock to her nerves and nervous system. 14. As a result of thc negligence of thc Defendant, thc Plaintiff was forced to incur medical bills and expenses for the injuries she has suffered, and she will continue to incur medical expenses in the future. 15. As a result of the negligence of thc Defendant, the Plaintiff has suffered, or may suffer, a severe loss of her earnings and impairment of her earning capacity and the loss of income and impairment of earning capacity will, or may continue in the future. 16. As a result of the negligence of the Defendant, the Plaintiff has undergone, and in the future may undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily activities, all to her great loss and detriment. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment against the Defendant in an amount in excess of thc mandatory arbitration limits. COUNT II CHRISTINA MARIE BELL, a minor by her mother and natural guardian, WANDA BELL V. DARYL RHEY RHINE 17. The allegations contained in paragraphs 1 through 16, inclusive, are incorporated herein as fully as though set forth at length. 18. As a result of the negligence of the Defendant, the Plaintiff suffered serious and permanent injuries including but not limited to neck injuries, shoulder injuries, and a severe shock to her nerves and nervous system. 19. As a result of the negligence of the Defendant, the Plaintiff was forced to incur medical bills and expenses for the injuries she has suffered, and she will continue to incur medical expenses in the future. 20. As a result of the negligence of the Defendant, the Plaintiff has suffered, or may suffer, a severe loss of her earnings and impairment of her earnings capacity and loss of income and impairment of earning capacity will, or may, continue in the future. 21. As a result of the negligence of the Defendant, the Plaintiff has undergone, and in the future may undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily activities, all to her great loss and detriment. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment tgainst the Defendant in an amount in excess of the mandatory arbitration limits. RESPECTFULLY SUBMITTED: LAW OFFICES OF DALE E. ANSTINE, P.C. Attorney I.D.//29176 Two West Market Street P.O. Box 952 York, Pennsylvania 17405 (717) 846- 0606 I HEREBY VERIFY that the information set forth in the foregoing Complaint is true and correct to the best of my knowledge, information and belief. I understand that any false statements contained herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Wanda Bell, mother and natural guardian of Christina Marie Bell SHERIFF'S RETURN - REGULAR CASE NO: 2003-00774 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BELL MURDINA ANN ET AL VS RHINE DARYL RHEY CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RHINE DARYL RHEY the DEFENDANT , at 131 ZION ROAD NEWBURG, PA 17240 at 1856:00 HOURS, on the 4th day of March , 2003 by handing to STESI R RHINE, MOTHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.49 Affidavit .00 Surcharge 10.00 .00 42.49 Sworn and Subscribed to before me this /0~ day of A.D. ~ ~rothonotary ' So Answers: R. Thomas Kline 03/05/2003 DALE E ANSTINE By: ' ~ '~ v De~y Sher~f MURDINA ANN BELL and CHRISTINA MARIE BELL, a minor, by her parent and guardian, WANDA BELL, Plaintiffs DARYL RHEY RHINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-774 CIVIL ACTION - LAW JURY TRIALDEMANDED PRAECIPE FOR ENTRY OF APPEARANCF TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Daryl Rhey Rhine, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. Date: By: M~iich~a~e I S.~Fe ~gu'~s n~, Esqu ire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 (7! 7) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 19th day of March, 2003, I hereby certify that I have served the foregoing Praecipe to Enter Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Leah B. Graft, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market St. York, PA 17405 ' ~~.,~Es uire M~chael S Fergu , q MURDINA ANN BELL and CHRISTINA MARIE BELL, a minor, by her parent and guardian, WANDA BELL, Plaintiffs DARYL RHEY RHINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-774 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD To: Murdina Ann Bell, Christina Marie Bell and Wanda Bell Leah B. Graft, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market St. York, PA 17405 YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Date: By: Respectfully submitted, NEALON & COVER, P.C. '~'M~ich(~ael S .~Ferg~us~,, Esqu ire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 MURDINA ANN BELL and CHRISTINA MARIE BELL, a minor, by her parent and guardian, WANDA BELL, Plaintiffs DARYL RHEY RHINE, Defendant AND NOW, comes IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-774 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER the Defendant, Daryl Rhey Rhine, by and through his attorneys, Nealon & Gover, P.C., and in response to Plaintiff's Complaint, avers the following: 1. 2. 3. 4. 5. 6. Admitted on information and belief. Admitted on information and belief. Admitted on information and belief. Admitted. Admitted on information and belief. Admitted in part. By way of further answer the Defendant was operating a 1989 Toyota Camry. 7. Admitted in part and denied in part. It is admitted that on July 24, 2002 Murdina Bell and Christina Bell backed out of a driveway located on the east side of Jumper Road. All other averments in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). 8. Denied pursuant to Pa.R.C.P. 1029(e). 9. Denied. This is a conclusion of law to which no responsive pleading is required. To the extent that any of the averment is considered factual in nature it is specifically denied pursuant to Pa.R.C.P. 1029(e). 10. Denied. This is a conclusion of law to which no responsive pleading is required. To the extent that any of the averment is considered factual in nature it is specifically denied pursuant to Pa.R.C.P. 1029(e). 11. Denied. This is a conclusion of law to which no responsive pleading is required. To the extent that any of the averment is considered factual in nature it is specifically denied pursuant to Pa.R.C.P. 1029(e). COUNT I MURDINA A. BELL v. DARYL RHEY RHINE 12. The answers contained in paragraphs 1 through 11 inclusive are incorporated herein by reference. 13.-16. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant, Daryl Rhey Rhine, respectfully requests that this Honorable Court dismiss the Complaint against him with prejudice. COUNT II CHRISTINA MARIE BELL~ a Minor by her Mother and Natural Guardian, WANDA BELL v. DARYL RHEY RHINE 17. The answers contained in paragraphs 1 through 16 inclusive are incorporated herein by reference. 18.-21. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant, Daryl Rhey Rhine, respectfully requests that this Honorable Court dismiss the Complaint against him with prejudice. 22. The answers contained incorporated herein by reference. NEW MATTER in paragraphs 1 through 21 inclusive are Date: 23. Plaintiff's claims may be barred in part or in whole by application of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. § 1701 et seq. WHEREFORE, Defendant, Daryl Rhey Rhine, respectfully requests that this Honorable Court dismiss the Complaint against him with prejudice. Respectfully submitted, NEALON & GOVER, P,C. Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, Daryl Rhey Rhine, verify that the statements made in the foregoing Answer with New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: Daryl I~hey Rl~ine CERTIFICATE OF SERVICE AND NOW, this ~'J-_ day of April, 2003, I hereby certify that I have served the foregoing Answer on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Leah B. Graft, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market St. York, PA 17405 ~chael S g Esquire IN THE COURT OF COMMON PLEAS O] CUMBERLAND COUNTY, PENNSYLVANI MURDINA ANN BELL and CHRISTINA MARIE BELL, a minor, by her parent and guardian, WANDA BELL, Vo DARYL RHEY RHINE 22. 23. No. 03-774 CIVIL ACTION - ] JURY TRIAL DEI~ PLAINTIFFS' REPLY TO NEW MATTE~ No response is required. Denied. The allegation contained in Paragraph 23 is a c~ the Pennsylvania Rules of Civil Procedure require no responsive plead[ and strict proof thereof is demanded at trial, if relevant. LAW OFFICES OF DALi Respectfully Submitted: Attorney ID No. 29176 Two West Market Street P.O. Box 952 York, PA 17405 (717) 846- 0606 Attorney for the Plaintiffs ~AW lANDED inclusion of law to which ag, are therefore denied, E. ANSTINE, P.C. DAL~ E. AN~?IN~· P. C. I HEREBY VERIFY that the information set forth in the foregc Matter is true and correct to the best of my knowledge, information and any false statements contained herein are subject to the penalties of 18 l? unswom falsification to authorities. ing Reply to New belief. I understand that a.C.S. §4904, relating to Wanda Bell, moth Christina Marie B er and natural guardian of CERTIFICATE OF SERVICE., AND NOW, this 7th day of April, 2003, I, Leah B. Graft, Esquire, a mere Offices of Dale E. Anstine, P.C., hereby certify that I have this date served a cop,. foregoing document by first class United States mail, postage pre-paid, addresse~ attorney of record as follows: Michael S. Ferguson, Esq. Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 Respectfully submitted, LAW OFFICE OF DALE E. AN: Leah B. Graff, Esquire Attorney for Plaintiff ~er of the Law of the within and to the party or ;TINB, P.C. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 04--7~4 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/15/2003 Attorney for DEFENE~ANT DEll-44492~ 200 8 3 --LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-773 NOTICE OF IN'£~tNT TO SERVE A SUBPO]~]A TO PRODUCE ~S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CHAMBERSBURG HOSPITAL GERALD R. MATTIA CENTRE CARE PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and .serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/25/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA HOFFMAN - 03-169 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEPENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-239505 2 0 0 83--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. RHINE: File No. 03-773 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHAMBERSBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun. Inc._ 1601 Market Street. Suite 800. Philadelphia_ PA 19103 You may deliver or mail legible copies of the documents or produce tlfings requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON, ESQ. 2411 N. FRONT ST. HARRISBURG. PA 171 lQ TELEPHONE: (215'}246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Iq. ~ Seal of the Court BY THE COURT: Prothonotar~/C~k, Civil Div~'fi 20083-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL 112 NORTH SEVENTH ST. CHAMBERSBURG, PA 17201 RE: 20083 MURDINA ANN BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treamaent, admission, discharge, or emergency care pertaining to: Dates Re. quested: up to and including the present. Subject. MURDINA ANN BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 192-62-4512 Date of Birth: 06-02-1982 SU10-461075 20 0 83--L0 1 CERTIFICATE PRERROUISITR TO SERVICE OF A SUBPOENA PURSUANT TO RULE 400~.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS- CASE NO: 03-773 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FEEGUSON, 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 Peen received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of i~.3~% ~o serve the subpoena. DATE: 09/15/2003 MCS on behalf of MICHAEL FERGUSON, ESQ.. Attorney for DEFENDANT DEll-444927 20 O 8 3 --LO 2 COMMONWEALTH OF PE~NSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS - COURT 0F COMMON PLEAS TERM, CASE NO: 03-773 NOTIC~ OF I~'r~fT TO SERV~ A SUBPOENA TO PRODUC~ ~S AND FOR DISCOVerY PURSUANT TO RUI~ 4009.2q CHAMBERSBURG HOSPITAL GERALD R. MATTIA CENTRE CARS PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON~ ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day no~ice 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: 08/25/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA HOFFMAN - 03-169 MCS on behalf of MICHaeL PERGUSON~ ES~. Attorney for DEPENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET PHILADELPHIA, PA 19103 (215) 246-0900 DE02-239505 2 O O 83 --CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. : File No. 03-773 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.~ TO: Custodian of Records for GERALD R. MATTIA, (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 RIDEI~ **** at The MCS Grouo. Inc._ 1601 Market Street_ Suite 800. Philadelnhla PA 19lQ) You may deliver or mail legible copies of the documents or produce ttfings requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESQ. 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: ,~ Prothonotary/Clerk, Civil Di~b"fi Deputy 20083-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GERALD R. MATTIA 8915 CONROY WINDERMERE RD ORLANDO, FL 32835 RE: 20083 MURDINA ANN BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical fde, including but not limited to any and all records correspondence to and from the consulting and treating physicians, ~es, memo.ra~.da, handwritten notes, history and physical reports, medication/ prescnpuon records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: MURDINA ANN BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: '192-62-4512 Date of Birth: 06-02-1982 SU10-461078 2 0 0 8 3 --LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS- CASE NO: 03~773 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FEEGUSON, 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: 09/15/2003 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-444928 200 8 3 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-773 NOTICE OF INT~TT TO SERV~ A SUBPOENA TO PRODUCE ~S AN~ FOR DISCOVI~RY PURS~NT TO RULE 4009.21 CHAMBERSBURG HOSPITAL GERALD R. MATTIA CENTRE CARE PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS MEDICAL RECOP. DS MEDICAL RECORDS MEDICAL RECORDS TO: LEAH B. GP~FF, ESQ. MCS on behalf of MIC}L~EL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day no~ice 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: 08/25/2003 CC: MICHAEL PRRGUSON, ESQ. PATRICIA BOFFMAN - 03-169 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKRT STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 Dg02-239505 200 83--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. File No. 03-773 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CENTRE CARE (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 RID]~t~ **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadeinhia_ PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESQ. 2411 N. FRONT ST. HARRISBLrRG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR.' Defendant Date: Seal of the Court BY THE CO.U~. T: ~ Prothonotary/Cle~kfCt~il D~n 20083-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTRE CARE 10000 W. COLONIAL DRIVE OCOEE, FL 34761 RE: 20083 MURDINA ANN BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and tr6ating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: MURDINA ANN BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social. ~Se~. rity #: 192-62-4512 Date of Birth: 06-02-1982 SU10-461080 2 0 0 8 3 --LO 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -rs - CASE NO: 03-773 AS a prerequisite to service of a subpoena for documents and thinps pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the.subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/15/2003 MCS on behalf of MICHAEL FERGUSON,. ESQ. Attorney for DEFENDANT DEll-444929 2 O O 8 3 --LO 4 COMMONWEALTH OF PE~INSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS- COURT OF COMMON PLEAS TERM, CASE NO: 03-773 NOTIC~ OF I~'rs~T TO SHRV~ A SUBPOENA TO PRODUC~ ~S ~ FOR DISCOVHRY PURSUANT TO RUI~I~ 4009.21 CHAMBERSBURG HOSPITAL GERALD R. MATTIA CENTRE CARE PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day no~ice 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: 08/25/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA EOFFNAN - 03-169 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-239505 20083--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. File No. 03-773 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PHYSICIANS INJURY CARE 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 Groun. Inc.. 1601 Market Street. Suite 800. Philadelvhia_ PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESQ. 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215'~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY ~ COLUR, T: /h Prothonotary/Clark, Civil D'i'vis~ov~ 20083-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PHYSICIANS INJURY CARE CENTER 5287 ALHAMBRA DRIVE ORLANDO, FL 32808 RE: 20083 MURDINA ANN BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical frie, including but not limited to any and all records correspondence to and from the consulting and treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: MURDINA ANN BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 192-62-4512 Date of Birth: 06-02-1982 SU10-461082 2 0 0 8 3 --LO 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BELL TERM, -VS- CASE NO: 03-774 RHINE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 NCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, includin9 the proposed subpoena, is attac~ed to this certificate, (3) NO objection to the ~ubpoena 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: 09/15/2003 MCS on behalf MICHAEL FERGUSON, Attorney for DEFEN~DANT DEll-444930 200 84 --LO 1 COMMONWEALTH OF PENS[SYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-774 NOTICE OF IRT~UqT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCO%/~KY PURSD-ANT TO RULE 4009.21 CHAMBERSEURG HOSPITAL GERALD R. MATTIA CENTRE CARE PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the t#enty 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: 00/25/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA HOFFMAN - 03-169 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regard/rig this matter, Contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-239506 20 0 84 --CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. File No. 03-774 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-~ TO: Custodian of Records for CHAMBERSBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days at, er 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 S~a'eet. 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 subpoem, 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 TIlE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON, ESQ. 2411 N. FRONT ST, HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SLrpREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court 1 rothonotary/Clerk, Civil Divisi~'''~ Deputy 20084-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL 112 NORTH SEVENTH ST. CHAMBERSBURG, PA 17201 RE: 20084 CHRISTINA MARIE BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, fries, memoranda, handwritten notes history and physical reports medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINA MARIE BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 202-68-1097 Date of Birth: 01-11-1988 SU10-461084 20084--L0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS- CASE NO: 03-774 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/15/2003 MCS on behalf of MICHAEL'FERGUSON, ESQ. Attorney for DEFENDANT DEll-444931 2 O O 84 --LO 2 COMMO'NWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -rs - COURT OF COMMON PLEAS TERM, CASE NO: 03-774 NOTICE OF I~-r~fT TO SER~q~ A SUBPOENA TO PRODUCE DO~uM]~TTS AN~ FOR DISCOVERY P~RSI]]~NT TO RUL~ 4009.9.1 CHAMBERSBURG HOSPITAL GERALD R. MATTIA CENTRE CARE PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS ~DICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LEAR B. GRAFF, ESQ. NCS On behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/25/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA EOFFMAN - 03-169 MCS on behalf of MICHAEL FERGUSON~ ESQ. Attorney for DEFENDANT ~ny questions regarding this matter, contact TEE MCS GROUP INC. 1G01 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-239506 20084--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. File No. 03-774 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GERALD R. MATTIA (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.. 160t 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 th/ngs 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: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N. FRONT ST, HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendarl~ Date: Seal of the Court BY THE COURT: ProthonOtary/Clerk, Civif'Div-is~ ? . 20084-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GERALD Ri MATTIA 8915 CONROY WINDERMERE RD ORLANDO, FL 32835 RE: 20084 CHRISTINA MARIE BELL Please call for prior approval for fees in excess of $100.00 for ihospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, fries, memoranda, handwritten notes, history and physical reports, ~?ication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINA MARIE BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social .~.urity #: 202-68-1097 Date of Birth: 01-11-1988 SU10-461086 2 0 0 8 4 --LO 2 CRRTIPICATR PRRRROUISITg TO SRRVICR OP A SUBPORNA PURSUANT TO RULH 400~.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS- CASE NO: 03-774 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (i) 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, includin9 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: 09/15/20'03 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-444932 2 O O 84 --LO 3 COMMONWEALTH OF PE~rNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-774 NOTICE OF I~'r=~'T TO SERVE A SUBPOENA TO PRODUCE DOCuM~TTS 2~ FOR DISCO~Y WuI(SUANT TO RDL~ 4009.21 CHAMBERSSURG HOSPITAL GERALD R. MATTIA CENTRE CARE PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS MEDICAL RECORDS ~DICAL RECORDS MEDICAL RECORDS TO: LEAH B. GRAFP, ESQ. NCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/25/2003 CC: MICHAEL FERGUSON, ESQ. PATEICIA EOPFNAN - 03-169 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 ~EET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-239506 20 0 8 4 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. FileNo. 03-774 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CENTRE CARE (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 Groum Inc.. 1601 Market Street. Suite 800. Philadelnhia PA 19103 YOU may deliver or mail legible copies of the documents or produce tlrdngs requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the fight 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 tbJs subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESQ. 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0~}00 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY TItE COURT: Prot h-o'ia~t ary/Clerk, 20084-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTRE CARE 10000 W. COLONIAL DRIVE OCOEE, FL 34761 RE: 20084 CHRISTINA MARIE BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, ~es, memoranda, handwritten notes, history and physical report, s, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINA MARIE BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 202-68-1097 Date of Birth: 01-11-1988 SU10-461088 20 0 84--L03 CgRTIFIC~Tg PR~R~0UISITH TO S~RVICg OF A SUBPOgNA PURSUANT TO RUL~ 400~.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS - CASE NO: 03-774 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served :s identical to the subpoena which is attached to the notice of intent %o serve the subpoena. DATE: o / s/2oo3 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-444933 2 0 0 84 --LO 4 COMMONWEALTH OF PE~TNSYLVANIA COUNTY OF CUMS~ERLAND IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-774 NOTICIE OF I~-£~fT TO SIERV~ A SUBPOENA TO PRODUCIE DOCUMENTS AND THINC~ FOR DISCO~t(~ PURSU9%NT TO RUId~ 4009.21 CHAMBERSBURG HOSPITAL GERALD R. MATTIA CENTRE CARE PHYSICIANS INJURY CARE CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intencls 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: 08/25/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA HOPFI~m~N - 03-169 Any questions regardiug this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-239506 2 0 0 8 4 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. FileNo. 03-774 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PHYSICIANS INJURY CARE 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-Groun. Inc.. 1601 Market Street_ Suite 800. Philadelphia_ p,~i 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 fight to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division 20084-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PHYSICIANS INJURY CARE CENTER 5287 ALHAMBRA DRIVE ORLANDO, FL 32808 RE: 20084 CHRISTINA MARIE BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physici~ms, fdes, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINA MARIE BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 202-68-1097 Date of Birth: 01-11-1988 SU10-461090 2 0 0 84 --LO4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUEPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BELL TERM, -VS- CASE NO: 03-774 CIVIL RHINE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/26/2003 AL~O n~ k~hal f/~ f/~/ Attorney for DEFEND)~NT / ~./ DEll-464407 2 O O 8 3 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: BELL RHINE -VS- C0URT OF COMMON PLEAS TERM, CASE N0: 03-774 CIVIL NOTICE OF Ilv£1s~iT TO SERVE A SUBPOENA TO PRODUCE DOCI]MI~S AND ~II~ FOR DISC~Y PI~o~/TT TO Rllh~ 4009.21 DREW MEDICAL, INC. GERALD R. NATTIA MEI FILM ONLY X-RAY ONLY TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. inteods 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 tweoty 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: 12/04/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA HOFFMAN - 03-169 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249450 2OO83--CO2 COMMONWEXLTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. RHINE: File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DREW MEDICAL. 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 Groum Inc.. 1601 Market Street. Suite 800. Philadelnhia_ PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the fight to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (~15~ 246-0900 SUPREME COURT ID #: ATFORNEY FOR: Defendant Seal of the Court Prothonotary/Clerk, Civil l~iv~ 20083-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DREW MEDICAL, INC. 7208 SAND LAKE RD. SUITE 102 ORLANDO, FL 32819 RE: 20083 MURDINA ANN BELL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all MRI films and repons, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis, consultation, care and/or treatment pertaining to: Dates Requested: up to and including the present. Subject: MURDINA ANN BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 192-62-4512 Date of Birth: 06-02-1982 SU10-477342 2 0 0 8 3 --LO 5 CgRTIFICATR PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS - CASE NO: 03-774 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/26/2003 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-464408 2 O O 8 3 --LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBE}~LAND IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-774 CIVIL NOTICE OF IN-rm~TT TO SERVE A SUBPOENA TO PRODUCE DOcuMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DREW MEDICAL, INC. GERALD R. MATTIA MRI FILM ONLY X-RAY ONLY TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena, may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/04/2003 CC: MICHAEL FERGUSON, PATRICIA HOFFMAN ESQ. - 03-169 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249450 2OO83--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. File No. SUBPOENA TO PRODUCE DOCUMENTS OR TltlI'qGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GERALD R. MATTIA (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. Philadeinhia. 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 paxty making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESQ. 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Prothonomry/Clerk~ IEiv~l~ Seal of the Court 20083-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GERALD R. MATTIA 8915 CONROY WINDERMERE RD ORLANDO, FL 32835 RE: 20083 MURDINA ANN BELL 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: MURDINA ANN BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 192-62-4512 Date of Birth: 06-02-1982 SU10-477344 2 0 0 8 3 --LO 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS - CASE NO: 03-774 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/26/2003 DEll-464409 200 84--LO5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS - COURT OF COMMON PLEAS TERM, CASE N0: 03-774 NOTICE OF I~'r~TT TO SERVE A SUBPOENA TO PRODUCE DOCI~W~TS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CHAMBERSBURG HOSPITAL GERALD R. MATTIA X-RAY ONLY X-PAY ONLY TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/04/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA HOFFMAN - 03-169 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #000 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249451 2 O O 84 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : RHINE: File No. 03-774 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHAMBERSBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS 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: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N. FRONT ST, HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court B55HEcoUR? , - Pro?onotary/Cler~, C/vi~lDivisionu 20084-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL 112 NORTH SEVENTH ST. CHAMBERSBURG, PA 17201 RE: 20084 CHRISTINA MARIE BELL 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, perishing to: Dates Requested: up to and including the present. Subject: CHRISTINA MARIE BELL 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 202-68-1097 Date of Birth: 01-11-1988 SU10-477346 2 0 0 84--L0 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BELL COURT OF COMMON PLEAS TERM, RHINE -VS- CASE NO: 03-774 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/26/2003 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT EEll-464410 200 84 --LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BELL RHINE -VS- COURT OF COMMON PLEAS TERM, CASE NO: 03-774 NOTICE OF INT~Z~-T TO SER3/E A SUBPOENA TO PRODUCE DOCUMENTS AND THIN~S FOR DISCO%~k~KY PURSUAI~T TO I~lJLE 4009.21 CHAMBERSBURG HOSPITAL GERALD R. MATTIA X-RAY ONLY X-RAY ONLY TO: LEAH B. GRAFF, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/04/2003 CC: MICHAEL FERGUSON, ESQ. PATRICIA HOFFMAN - 03-169 MCS on behalf of MICHAEL FHRGUSON, ESQ. Attorney for DEFENDANT Any questions regard/rig this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249451 2OO 84--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BELL : VS. RHINE: File No. 03-774 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GERALD R. MATFIP~ (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 ;[9103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days aRer its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESQ. 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defend~rlt B~E~4 j~COURT: ^ pr~th~no,xry/CYerks divil Divisio~/] Seal of the Court 20084-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GERALD R. MATTIA 8915 CONROY WINDERMERE RD ORLANDO, FL 32835 RE: 20084 CHRISTINA MARIE BELL 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 f'dms 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: CHRISTINA MARIE BELI~ 7515 REDWOOD COUNTRY ROAD, ORLANDO, FL 32835 Social Security #: 202-68-1097 Date of Birth: 01-11-1988 SU10-477348 2 0 0 84--L06 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MURDINA ANN BELL and CHRISTINA MARIE BELL, a minor, by her parent and guardian, WANDA BELL, Vo DARYL RHEY RHINE No, 03-774 ClX/IL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE To The Prothonotary: Please mark the above-captioned action settled and satisfied. Respectfully submitted, Leah B~.-CJraff, l~s~lui~e ~' -- Attorney I.D. No. 29176 Two West Market Street P.O. Box 952 York:, Pennsylvania 17405 (717) 846-0606 Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this 17th day of December, 2004, I, Leah B. Graff, Esquire, a member of the Law Offices of Dale E. Anstine, P.C., hereby certify that 1[ have this date served a copy of the within Praecipe by first class United States mail, postage pre~paid, addressed to the party or attorney of record as follows: Michael S. Ferguson, Esq. Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 Respectfully submitted, LAW OFFICE OF DALE E. ANSTINE, P.C. Leah B. Graff, Esquire Attorney for Plaintiff 2