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HomeMy WebLinkAbout03-1164JANET RADABAUGH, : Plaintiff/Petitioner : : V. : : LORIE RADABAUGH, : Defendant/Respondent : IN RE: IN THE COURT OF COM/4ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-1164 CIVIL TERM TEMPORARY CUSTODY QRDER OF COURT AND NOW, this 17th day of March, 2003, after conference between the parties, it is ordered and directed that the parties shall share legal custody of Shania Radabaugh, born September 13, 1995. Pending further order of court, Janet Radabaugh shall have primary physical custody of the Child, subject to partial physical custody in Lorie Radabaugh as follows: Every Saturday from 9:00 a.m. until 5:00 p.m. Every Sunday from noon until 5:00 p.m. Every Tuesday from after school until 8:00 p.m. When Lorie Radabaugh has obtained an apartment with appropriate living arrangements for the Child, she may have physical custody of the Child from the first Sunday of every month at 6:00 p.m. until the second Sunday of every month at 6:00 p.m. This partial custody shall be in lieu of the weekend custody set forth above. During the times that Mother has physical custody of the Child for one week at a time, it shall be her responsibility to see that she makes it to and from school at the Newville Elementary. This is a temporary Order only and shall not be deemed in any way to affect the rights of the parties at the upcoming conciliation, or the upcoming hearing to be held before this Court if the conciliation is not successful. The Court Administrator is directed to schedule this matter for conciliation as soon as practical. Neither party shall remove the Child from this Court's jurisdiction. Nicholas Aloia, Certified Legal Intern Lucy Johnston-Walsh, Esquire Family Law Clinic For Plaintiff/Petitioner Lorie Radabaugh P.O. Box 941 Carlisle, PA 17013 Defendant/Respondent, Pro se Court Administrator srs SHERIFF'S RETURN - REGULAR CASE NO: 2003-01164 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RADABAUGH JANET VS RADABAUGH LORIE BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within ORDER AND PETITION was served upon RADABAUGH LORIE the RESPONDENT , at 2116:00 HOURS, on the 14th day of March at APPALACHIAN MOTOR INN 1825 HARRISBURG PIKE CARLISLE, PA 17013 by handing to LORIE RADABAUGH , 2003 a true and attested copy of ORDER AND PETITION together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this /. ~ day of ~ J Pr6thc~qo~ary /~ So Answers: R. Thomas Kline 03/17/2003 FAMILY LAW By: D Sheriff JANET RADABAUGH, Plaintiff, Petitioner LORIE RADABAUGH, Defendant, Respondent · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION LAW PLAINTIFF'S COMPLAINT FOR CUSTODY The Plaintiff, Janet Radabaugh, through her attorneys the Family Law Clinic, sets forth the following causes of action: 1. The Plaintiff is Janet Radabaugh, (hereinafter "Grandmother") residing at 177 CME, Newville, Cumberland County, Pennsylvania, 17241. 2. The Defendant is Lorie Radabaugh, (hereinafter "Mother") currently staying at Appalachian Motor Inn, 1825 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, 17013 3. Plaintiff seeks custody of the following child: Name Present Residence Shaina Radabaugh 177 CME, Newville, PA, 17241 Date of Birth September 13, 1995 The child was bom out of wedlock· The child resides with Grandmother, pursuant to a series of agreements between the parties, the first of which was executed December 29, 1999, with subsequent agreements being executed on April 20, 2001 and August 6, 2002, in which Mother made Grandmother legal guardian of the child· (Copies of the agreements are attached hereto as Plaintiff's Exhibit A and incorporated herein by reference.) In addition to the written agreements, Grandmother and Mother entered into a verbal agreement, whereby Mother takes the child from Monday through Friday, during those times in which Mother is off the road. The child is presently in the temporary control of LolSe Radabaugh, who is currently staying at the Appalachian Motor Inn, 1825 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, 17013. During the past five years, the child has resided with the following persons and at the following addresses: Persons Janet Radabaugh Lorie Radabaugh Janet Radabaugh Lorie Radabaugh Address 177 CME, Newville, PA, 17241 "on the road" 177 CME, Newville, PA, 17241 500 Cherry Court, Carlisle, PA 17013 Dates September 2001-Present April 2001-August 2001 December 1999-March 2001 1998-November 1999 The mother of the child is currently staying at Appalachian Motor Inn, 1825 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania, 17013. The mother is single. The father of the child is Darren Green, whose whereabouts are unknown, and who has not seen the child for over six years, and who has not been named as a party. The father's marital status is not known. 4. The relationship of the plaintiff to the child is that of maternal grandmother. The plaintiff resides with the following persons: Name Shaina Radabaugh Relationship granddaughter 5. The relationship of the defendant to the child is that of biological mother. The defendant is currently staying with the following persons: Name Relationship Benjamin Wright boyfriend Eric Radabaugh son In addition, on March 7, 2003, Mother, pursuant to the verbal agreement she has with Grandmother, took control of the child for what was to have been one week. Grandmother, believing that the child would be returned acquiesced to Mother's request. However, on March 11, 2003, Mother told Grandmother, on the phone, that the child would not be returned. 6. The plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. The plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Mother is financially unable to care for the child. b) The child has established a strong psychological bond with Grandmother. c) Grandmother is more likely to encourage, permit, and allow frequent and continuing contact and physical access between Mother and the child, then Mother is to encourage ongoing contact between the child and Grandmother. d) Mother is currently living in a hotel, which is outside the child's school district. e) Mother has no job. f) Mother is unable to provide the child with permanent housing. g) Grandmother is employed. h) Grandmother is able to provide the child with a more stable living environment. i) Grandmother's residence is located in the child's school district. 8. The mother whose parental rights to the child have not been terminated and the grandmother who stands in loco parentis to the child have been named as parties to this action. The biological father of the child, Darren Green, has had no contact with the child for over six years and his whereabouts are unknown, and counsel is unaware of any way to provide him with actual service, and therefore he has not been named as a party to this action. WHEREFORE, plaintiff respectfully requests this Court to grant her sole legal and primary physical custody of the child. March 14, 2003 Nicholas Aloia Certified Legal Intern ~. RAENS LUCY ]OHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION I certify that the statements made in Plaintiff's Custody Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsifaction to authorities. Plaintiff Exhibit Sworn and subscribed to befo~me this o~ ~t~:_. :"--.,...~'--r< ,, .. c -¥~~z>:< NOTARIAL SEAL I)^WN M. 8HUGHART, Notary Public Carlisle, Cumberland County My Commission Expires Nov. 28, 2002 Exhibit Exhibit ' NoYARi~LSEAL ~i~Jchelle L Sollenberger, Notary Public Fayetteville, ~mklin County .... ' C°mm!ssi~[! .E_Xl~)ires Oct. 5, 200~ JANET RADABAUGH, Plaintiff Vo LORIE RADABAUGH Defendant · IN THE COURT OF COMMON PLEAS · OF CUMBERLAND COUNTY, · PENNSYLVANIA · CIVIL ACTION - LAW IN CUSTODY NO. [-)-,-/Jbq CIVIL TERM ORDER OF COURT AND NOW, this __ day of ,2002, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at on the ~ day of ,2002, at m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order· Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FORTHECOURT: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU' CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any heating or business before the court. You must attend the scheduled conference or hearing. JANET RADABAUGH PLAINTIFF LORIE RADABAUGH DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-1164 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 27, 2003 , upon cm~sideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, April 17, 2003 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children are five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Hubert X. Gilroy, E. sq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 170.13 Telephone (717) 249-3166 JANET RADABAUGH PLAINTIFF, LORIE RADABAUGH, DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1164 C, IVIL LAW ACTION IN CUSTODY PRAECIPE TO ENTER APPEARANCE I, Joan Carey, of MidPenn Legal Services, enter my appearance as counsel of record for Lorie Radabaugh, defendant in the above captioned matter. Date: ~/~9~ By: ~ ~' rey v Attorney at Law MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 JANET RADABAUGH, Plaintiff, Petitioner V. LORIE RADABAUGH, Defendant, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW : No. 03 - 1164 CERTIFICATE OF SERVICE I, Nicholas Aloia, hereby certify that on this date I am serving a true and correct copy of Order of Court of April 30, 2003 on .the Defendant, by first class mail, addressed as follows. Lode Radabaugh Appalachian Motor Inn 1825 Harrisburg Pike Carlisle, PA 17013 Nicholas Aloia Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 MAY 1 3 2003 ' JANET RADABAUGH, Plaintiff v LORIE RADABAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 03 - 1164 CIVIL : IN CUSTODY COURT ORDER AND NOW, this ~t~''~s'k day of May, 2003, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that this court's prior order of March 17, 2003 shall remain in effect subject to the following modifications: Mother's periods of temporary custody on Tuesday evening shall be eliminated from the order. However, Mother's periods of temporary custody on Saturday shall be from 9:00 a.m. until 7:00 p.m. and on Sunday from Noon until 7:00 p.m. Additionally, Mother shall enjoy periods of temporary custody at such times as agreed upon by the parties. Once Mother obtains a separate living arrangement and in accordance with the March 17, 2003 Order, the custody order shall immediately change at that point consistent with the terms of the March 17, 2003 Order. Additionally, counsel for the parties may contact the conciliator at that time via a letter to request another custody conciliation conference if the parties are unable to reach a permanent order. Mother should notify the Maternal Grandmother immediately upon Mother being advised that she is unable to fulfill her obligations under the custody order by taking the minor child into custody. If possible, Mother shall give Maternal Grandmother at least 24 hours notice. Edward E. Guido CC: ~ ~za~e Rhoads ~Dickinson School of Law Family Law Clinic l~oan Carey, Esquire o6-15- JANET RADABAUGH, Plaintiff V LORIE RADABAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 03 - 1164 CIVIL IN CUSTODY Prior Judge: Edward E. Guido CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the child who is the subject of this litigation is as follows: Shaina Radabaugh, born September 13, 1995. A Conciliation Conference was held on May 9, 2003, with the following individuals in attendance: The Maternal Grandmother, Janet Radabaugh, with her counsel, Suzanne Rhoads, of the Dickinson School of Law Family Law Clinic; and the Mother, Lorie Radabaugh, with her counsel, Joan Carey, Esquire. The parties agree to the entry of an order in the form as attached. Custody ~o~squire CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU~a%IT TO RIILE 4009.22 IN THE MATTER 0F: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, 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, including the proposed subpoena, is attached to thi~ 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: 07/20/2004 Atto~e¥ for DEFENDANT DEll-504860 31068--L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: DONNA DEVINE CELESTE JEFFERSON -VS - COURT OF COMMON PLEAS TERM, CASE NO: CV-03-1164 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND FOR DISCov~KY mURSUANT TO R3~J~E 4009.2] [ Note: see enclosed list of locations ] TO: LORI A. REXROTR, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISHARD, 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 ye,ur expense by completing the attached counsel card and returning same to MCS er by contacting our local MCS office. DATE: 06/30/2004 CC: DARRYL R. WISHARD, ESQ. DARYL STUTES - 17699 - 15542339141 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-270534 3 10 6 8 -- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SUN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRAWBRIDGE FAMILY PRACTICE SUSQUEHANNA PRY. THERAPY ANNA BARRETT, MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DB~'2-270534 3 1 0 6 8 -- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEVINE VS. CELESTE JEFFERSON File No. : CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2? TO: Custodian of Records for WEST BRANCH NEUROLOGY ASSOC. (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 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: DARRYL R. WISHARD, ESQ. 10 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: JUL 2 Z304 Seal of the Court BY THE COURT: th~notary/Clerk, Civil Division Deputy 31068-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WEST BRANCH NEUROLOGY ASSOC. 1824 E. THIRD ST. WILLIAMSPORT,, PA 17701 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating 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: DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510892 3 1068--L1 0 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TEEM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and thin~s pursuant to Rule 4009~22 MCS on behalf of DARRYL R. WISHARD, 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 subpQena, 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: 07/20/2004 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT DEll-504861 3 10 6 8 --L1 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBEr[LAND IN THE MATTER 0P: DONNA DEVINE CELESTE JEFFERSON -VS- COURT 0F COMMON PLEAS TERM, CASE NO: CV-03-1164 NOTICE OF INT~4qT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AN~ FOR DISCOI/~K¥ PURSUANT TO RI[ILl{ 4009.2] [ Note: see enclosed list of locations ] TO: LORI A. REXROTH, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISHARD, 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: 06/30/2004 CC: DARRYL R. NISHARD, ESQ. DARYL STUTES - 17699 - 15542339141 Any questions regard/ng this matter, contact MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-270534 3 1 O6 8 --CO 2 LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SUN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRAWERIDGE FAMILY PRACTICE SUSQUEHANNA PHY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE§2-270534 31068--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEVINE VS. CELESTE JEFFERSON File No. CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.27 TO: Custodian of Records for SOCIAL SECURITY ADMINISTIL&TION (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 i[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 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: DARRYL R. WISHARD, ESQ. 10 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215~ 246-0900 SUPREME COURT 1D #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: Proth{~mry/Clerk, Civil Division Deputy 31068-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SOCIAL SECURITY ADMINISTRATION 1234 MARKET STREET 20TH FLOOR PHILADELPHIA, PA 19107 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire disability file, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, applications, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510894 3 1 0 6 8 --L1 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, ESQ. certifies that (1) ~ 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: 07/20/2004 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT DEll-504862 3 1 O 6 8 --L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: DONNA DEVINE CELESTE JEFFERSON -VS- COURT 0F COMMON PLEAS TERM, CASE N0: CV-03-1164 NOTICE OF I/~T~ZdT TO SERVE A SUBPOENA TO PRODUCE ~S ~ DISCOVERY PURS~ TO RI~ 4009.21 [ Note: see enclosed list of locations ] TO: LORI A. REXROTH, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISHARD, 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: 06/30/2004 CC: DARRYL R. WISHARD, DARYL STUTES ESQ. - 17699 - 15542339141 Any questions regard/ng this matter, contact MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-270534 3 10 6 8--CO2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SUN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRAWBRIDGE FAMILY PRACTICE SUSQUEHANNA PHY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-270534 3 1 0 6 8--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEVINE VS. CELESTE JEFFERSON File No. CV-03~I 164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2~ TO: Custodian of Records for SUN ORTHOPEDIC GROUP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by thc court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun. Inc._ 1601 Market Street. Suite 800. Philadelohia. 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: DARRYL R. WISHARD, ESQ. 10 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215~} 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: JUL 2 0 Seal of the Court BY THE COURT: Pr-oth~otary/Clerk, Civil Division Deputy 31068-12 EXPLANATION OF REQUIRED ]RECORDS TO: CUSTODIAN OF RECORDS FOR: SUN ORTHOPEDIC GROUP 900 BUFFALO ROAD LEWISBURG, PA 17837 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $I00.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physiciam;, files, memoranda, handwritten notes, history and physical repons, medication/ prescription records, including any and all such items as may be stored in a cff~pute, r database or otherv, i.se in electronic form, relating to any' examination, magnos~s or treatment pertaining to: Dates Requested: upto and including the present. Subject: DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510896 31068 --L12 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, 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: 07/20/2004 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT DEll-504863 3 1068--L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: DONNA DEVINE CELESTE JEFFERSON -VS- COURT OF COMMON PLEAS TERM, CASE NO: CV-03-1164 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND T~tJ--N~S FOR DISCOVERY PURSUi~NT TO RULE 4009.21 [ Note: see enclosed list of locations ] T0: LORI A. REXROTH, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISEARD, 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: 06/30/2004 CC: DAHRYL H. WISEARD, ESQ. DARYL STUTES - 17699 - 15542339141 MCS On behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT Any questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-270534 3 10 6 8--CO 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SY/N ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRAWBRIDGE FAMILY PRACTICE SUSQUEHANNA PHY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-270534 31068--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEViNE VS. CELESTE JEFFERSON File No. CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUiLE 4009_2'~ TO: Custodian of Records for DAVID LIGHTMAN. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED R/DER **** at The MCS Group. 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 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: DARRYL R. WlSHARD, ESQ. 10 WEST THIRD STREET WlLLIAMSPORT. PA 17701 TELEPHONE: (215~} 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: JUl, 2 g 2COq Seal of the Court BY THE COURT: P~oth0notary/Clerk, Civil I~vision Deputy 31068-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID LIGHTMAN, M.D. 1705 WARREN AVE. SUITE 302 WILLIAMSPORT, PA 17701 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical ~e, including but not limited to any and all records, correspondence to and from the consulting and treating physicians;, files, memoranda, handwritten notes, histo~ and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, .relating to any examination, diagnosis or treatment pertaining to: ~ua. tes Requested: up to and including the present. bject: DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510898 3 1 0 6 8 --L1 3 C~RTIFICAT~ FR~R~0UI$IT~ TO SERVICR OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, 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: 07/2022004 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT DEi1-504864 3 1 0 6 8 --L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBEF[LAND IN THE MATTER OF: DONNA DEVINE CELESTE JEFFERSON -VS- COURT OF COMMON PLEAS TERM, CASE NO: CV-03-1164 NOTICE OF INT~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: LORI A. RRXROTH, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISHARD, 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: 06/30/2004 CC: DARRYL R. WISHARD, DARYL STUTES ESQ. - 17699 - 15542339141 Any questions regarding this matter, contact MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-270534 3 1 O 6 8 --CO 2 LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SUN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGEE MEDICAL CENTER STRAWBRIDGE FAMILY PRACTICE SUSQUEHANNA PRY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-270534 31068--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEVINE VS. CELESTE JEFFERSON File No. CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MCCANN SCHOOL OF BUSINESS (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 §00. Philadelnhia. 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 produchig 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 FOLLOWTNG PERSON: NAME: ADDRESS: DARRYL R. WlSHARD, ESQ. 10 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215~ 246-0900 SLrPREME COURT ID #: ATTORNEY FOR: Defendant Date: J{J}.. 2 8 280¢ ' Seal of the Court BY THE ,COURT: P~-oth0hotary/Clerk, Civil l~i~'ision Deputy 31068-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MCCANN SCHOOL OF BUSINESS 2225 MARKET ST., #3 SUNBURY, PA 17801 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire scholastic ~e, including but not limited to files, memoranda, correspondence, notes, records relating to attendance, student history and/or transfers, grades, merits, awardS, disciplinary, medical/physicals, 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 :DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510900 3 1068--L14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUEPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE N0: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, 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: 07/20/2004 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney' for DEFENDANT DEll-504865 3106 8--L15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: DONNA DEVINE CELESTE JEFFERSON -VS- COURT OF COMMON PLEAS TERM, CASE NO: CV-03-1164 NOTICE OF INT~NT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUi~NT TO R'DLE 4009.21 [ Note: see enclosed list of locations ] TO: LORI A. REXROTH, ESQ., PLAINTIFF C0UNSEL MCS on behalf of DARRYL R. WISHARD, 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: 06/30/2004 CC: DARRYL E. WISHARD, ESQ. - 17699 DARYL STUTE$ - 15542339141 Any questions regarding this matter, contact MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET PHILADELPHIA, PA 19103 (215) 246-0900 DE02-270534 3 10 6 8 -- C O 2 LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SUN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRAWBRIDGE FAMILY PRACTICE SUSQUEHANNA PHY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS ~4EDICAL RECORDS DE02-270534 3 i 0 6 8 -- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEVINE VS. CELESTE JEFFERSON File No. CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GEISINGER MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun. 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 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: DARRYL R. WISHARD, ESQ. 10 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: JUL 2 0 Seal of the Court BY THE COURT: Prothd&otary/Clerk, Civil Division Deputy 31068-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GEISINGER MEDICAL CENTER NEUROLOGY DEPARTMENT 100 N. ACADEMY AVE. DANVILLE, PA 17822 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical f'fle, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical repons, medJication/ 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: ~ua. tes Requested: up to and including the present. bject: DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-511638 3 1068--L15 CERTIFICATE PREREQUISITE TO SERVICE OF A SUEPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, 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: 07/20/2004 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT DEll-504866 3 10 6 8 --L1 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: DONNA DEVINE CELESTE JEFFERSON -VS- COURT OF COMMON PLEAS TERM, CASE NO: CV-03-1164 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO R1ULE 4009.21 [ Note: see enclosed list of locations ] TO: LORI A. REXROTH, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISHARD, 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: 06/30/2004 CC: DARRYL R. WISHARD, ESQ. DARYL STUTES - 17699 - 15542339141 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DRI02-270534 3 10 6 8--CO 2 LOCATION LIST <<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SLTN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRAWBRIDGE FAMILY PRACTICE SUSQUEHANNA PHY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-270534 3 1 0 6 8 -- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEVINE VS. CELESTE JEFFERSON File No. CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-~ TO: Custodian of Records for STRAWBRIDGE FAMILY PRACTICE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by thc court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun_ Inc.. 1601 Market Street. Suite 800. Philadelnhia. PA 19109 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: ADDRESS: DARRYL R. WISHARD, ESQ. 10 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215~ 246-0900 SUPREME COURT 1D #: ATTORNEY FOR: Defendant Date: Jill 0 200tt Seal of the Court BY THE COURT: otary/Clerk, Civil Division Deputy 31068-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STRAWBRIDGE FAMILY PRACTICE 998 STRAWBRIDGE RD., NORTHUMBERLAND, PA 17857 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire 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, 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: DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510904 3 1068--L16 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, 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 :~ubpoena is sou§ht to be served, (2) A copy of the notice of intent, includin§ tine 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 serw~ the subpoena. DATE: o / o/ oo4 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT DEll-504867 3 10 6 8 --L1 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBER~LAND IN TEE MATTER OF: DONNA DEVINE CELESTE JEFFERSON -VS - C0URT 0F COMMON PLEAS TERM, CASE N0: CV-03-1164 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: LORI A. REXROTH, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISHARD, 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 tweuty 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: 06/30/2004 CC: DARRYL R. WISHARD, ESQ. DARYL STUTES - 17699 - 15542339141 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1G01 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 D~02-270534 3 1 O 6 8--CO2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED NEST BRACH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SUN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRAWBRIDGE FAMILY PRACTICE SUSQUEHANNA PHY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-270534 3 1 0 6 8 --C0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEVINE VS. CELESTE JEFFERSON File No. CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SUSOUEHANNA PHY. THERAPY (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. Philadelnhia. 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 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: DARRYL R. WISHARD. ESO. 10 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ' Seal of the CouP: BY THE COURT: P~oth0notary/Clerk, Civii'-D'i~,is~n Deputy 31068-17 EXPLANATION OF REQUIRED gECORDS TO: CUSTODIAN OF RECORDS FOR: SUSQUEHANNA PHY. THERAPY 1 FORESTWOOD DRIVE LEWISBURG, PA 178378906 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians;, fries, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be s;tored in a computer database or otherwise in electronic form, relating to an) examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510906 3 10 6 8--L17 C~RTI?ICAT~ ~R~R~0UI$IT~ TO SERVIC~ OF ~ SUBPOENA PURSUANT TO RUL~ 400).22 IN THE MATTER OF: DONNA DEVINE COURT OF COMMON PLEAS TERM, -VS- CELESTE JEFFERSON CASE NO: CV-03-1164 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DARRYL R. WISHARD, 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: 07/2~/2004 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT DEll-504868 31068 --L18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: DONNA DEVINE CELESTE JEFFERSON -VS- COURT OF COMMON PLEAS TERM, CASE NO: CV-03-1164 NOTICE OF IN'~'~NT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: LORI A. REXROTH, ESQ., PLAINTIFF COUNSEL MCS on behalf of DARRYL R. WISHARD, 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: 06/30/2004 CC: DARRYL R. WISHARD, ESQ. DARYL STUTES - 17699 - 15542339141 MCS on behalf of DARRYL R. WISHARD, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET PHILADELPHIA, PA 19103 (215) 246-0900 DE02-27~534 3 1 O 6 8 --CO 2 >>> LOCATION LIST <<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED WEST BRANCH NEUROLOGY ASSOC. SOCIAL SECURITY ADMINISTRATION SUN ORTHOPEDIC GROUP DAVID LIGHTMAN, M.D. MCCANN SCHOOL OF BUSINESS GEISINGER MEDICAL CENTER STRANBRIDGE FAMILY PRACTICE SUSQUEHANNA PHY. THERAPY ANNA BARRETT, M.D. MEDICAL RECORDS DISABILITY FILE MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS D3g02-270534 31068--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHUMBERLAND DONNA DEV1NE VS. CELESTE JEFFERSON File No.. CV-03-1164 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ANNA BARRETT. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS 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: DARRYL R. WISHARD. ESO. l0 WEST THIRD STREET WILLIAMSPORT. PA 17701 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: ~r-oth-~otary/Cler~, Civil Division Deputy 31068-18 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ANNA BARRETT, M.D. HERSHEY MEDICAL CENTER 500 UNIVERSITY DR. HERSHEY, PA 17033 RE: 31068 DONNA DEVINE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all recorcls, correspondence to and from the consulting and treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all tach items as may be :stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dat.es Requested: up to and including the present. Subject :DONNA DEVINE P.O. BOX 424, LEWISBURG, PA 17837 Social Security #: 156-56-3315 Date of Birth: 08-01-1969 SU10-510908 3106 8--L18