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Home My WebLink About03-1552IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERESA L. MATHEWS, Plaintiff Civil ActionwLaw vs. No. C~ ~ - /-~'-~"~ DEBRA L. FAILOR, Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Issue Writ of Summons in a Civil Action. The Defendant may be served at her residence or last known address: 1194 Myerstown Road, Gardners, Cumberland County, Pennsylvania. Fred H. H~it~ 1~34331" ' - Attorney for Plaintiff Hair & Puhala, P.C. The Wellington 1 7 East High Street, Suite 101 Carlisle, PA 17013-3047 (71 7) 249-4500 249-2411 (fax) pajoblawfh@earthlink.net Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS TERESA L MATHEWS Plaintiff Vs. Court of Common Pleas No. 03-1552 In CivilAction-Law DEBRA L FAILOR, 1194 MYERSTOWN ROAD, GARDNERS, PA Defendant To DEBRA L. FAILOR You are hereby notified that TERESA L MATHEWS the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date 4/04/03 Attorney: Name: FRED H. HAlT CURTIS R. LONG Prothonotary Address: 17 EAST HIGH STREET, SUITE 101 CARLISLE, PA 17013-3047 Attorney for: Plaintiff Telephone: (717) 249-4500 Supreme Court ID No. 34331 SHERIFF'S RETURN - REGULAR CASE NO: 2003-01552 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MATHEWS TERESA VS FAILOR DEBRA L BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon FAILOR DEBRA L the DEFENDANT at 1194 MYERSTOWN ROAD , at 1253:00 HOURS, on the 8th day of April , 2003 GARDNERS, PA 17324 by handing to RUBY RUPP, MOTHER a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 7 59 00 10 00 00 35 59 Sworn and Subscribed to before me this /~ ~ day of ~L~ ~? o2~O3 A.D. pfO~h0n~t ary~ / ~ So Answers: R. Thomas Kline 04/09/2003 FRED HAIT & ASSOCIATE,~By: ~~, Deputy Sheriff PAULINE E. KECK, Plaintiff Ye RONALD L. KECK, EXECUTOR OF THE ESTATE OF ARTHUR S. KECK, DECEASED, AND RONALD L. KECK, INDIVIDUALLY, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1522 EQUITY TERM CIVIL ACTION IN EQUITY DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW this day of April, 2003, comes Defendant, RONALD L. KECK, EXECUTOR OF THE ESTATE OF ARTHUR S. KECK, DECEASED and RONALD L. KECK, Individually, by and through his attorneys, Irwin, McKnight & Hughes, and makes the following Preliminary Objections to Plaintiff's Complaint, and in support thereof avers the following: Preliminary Objection in the Nature of a Demurrer Pursuant to Pa. R. Civ. P. 1028(a~(4). 1. Plaintiff, Pauline E. Keck, filed a civil complaint on or about April 3, 2003 against Defendants Ronald L. Keck in his capacity as the Executor of the Estate of Arthur S. Keck and against him individually, in summary alleging that Defendant, in his individual capacity as the sole legatee of the estate, will become unjustly enriched should he receive the estate assets. Executor by virtue of Letters Testamentary granted to him by the Register of Wills Cumberland County on January 7, 2003. 3. estate. Arthur S. Keck died testate on December 20, 2002, and Defendant was appointed of On or about March 3, 2003, Plaintiff filed a spousal election against Decedent's 4. Plaintiff has also filed numerous other petitions and pleadings in the Orphan's Court of Cumberland County with regard to Decedent's estate. 5. Nevertheless, in what is believed to be a further attempt to delay the proper administration of Decedent's estate, Plaintiff filed the instant action in equity only after the passing of Decedent. 6. The basis of all of Plaintiff's allegations are harms attributable to the alleged misconduct during the life of Decedent, Arthur S. Keck. 7. Plaintiff does not allege any tortious or otherwise improper conduct by Ronald L. Keck in his capacity as Executor of the estate of decedent that would give rise to a claim against said Ronald L. Keck in his individual capacity. 8. Plaintiff does not allege any improper action undertaken by Defendant Ronald L. Keck in his individual capacity that gives rise to Plaintiff's claim. 9. Plaintiff's Complaint falls to state any cause of action against Defendant upon which relief may be granted for the alleged abuses of Decedent. 10. Defendant preliminarily objects to Plaintiff's Complaint on the grounds that Ronald L. Keck, in both his individual capacity and as Executor of Decedent's estate, is not a proper party to this action and that the complaint is legally insufficient. WltEREFORE, Defendant Ronald L. Keck, respectfully requests this Honorable Court to grant his Preliminary Objections and dismiss Plaintiffs Complaint with prejudice. II. Preliminary Objection Raising Lack of Jurisdiction Pursuant to Pa. R. Civ. P. 1028(a)(1). 14. jurisdiction 11. Plaintiff's Complaint includes allegations that Defendant Ronald L. Keck is liable to Plaintiff by virtue of his having been appointed Executor of the Estate of Arthur S. Keck. 12. Plaintiff's Complaint includes an allegation in paragraph 20 that as Executor, Ronald L. Keck "holds title to all estate assets and is subject to an equitable duty to convey the same to Plaintiff." 13. Plaintiff's Complaint also alleges that Defendant Ronald L. Keck individually is the sole legatee under Decedent's Last Will and Testament. 20 Pa.C.S.A. § 711(1) provides that the Orphans' Court has mandatory over "the administration decedents' estates ...." 15. Furthermore, 20 Pa.C.S.A. and distribution of the real and personal property of § 711(17) provides that the Orphans' Court has mandatory jurisdiction over "the adjudication of the title to personal property in the possession of the personal representative, or registered in the name of the decedent or his nominee, or alleged by the personal representative to have been in the possession of the decedent at the time of his death." 16. Plaintiff's Complaint was not filed in the Cumberland County Orphans' Court which has mandatory jurisdiction over the claims raised by Plaintiff. WHEREFORE, Defendant Ronald L. Keck, respectfully requests this Honorable Court to grant his Preliminary Objections and dismiss Plaintiffs Complaint with prejudice. Dated: April 30, 2003 By: Respectfully Submitted, Marcus A~gl~ IlI,'~uire Supreme((~_ urt ID_No. 25476 West PonYfr~rofcssional Buildin~x~ 60 West Pomfre~C~-ce~ Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Defendant PAULINE E. KECK, : IN THE COURT OF COMMON PLEAS Plaintiff RONALD L. KECK, EXECUTOR OF THE ESTATE OF ARTHUR S. KECK, DECEASED, AND RONALD L. KECK, INDIVIDUALLY, Defendants : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1522 EQUITY TERM CIVIL ACTION IN EQUITY CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of foregoing document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Edward L. Schorpp, Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 Dated: April 30, 2003 By: IR~T & HUGHES Supreme Court ID No. 25476 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERESA L. MATHEWS, Plaintiff VSe DEBRA L. FAILOR, Defendant Civil ActionmLaw No. 03-1552 Civil Term TO: DEBRA L. FAILOR: NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland Count,/Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERESA L. MATHEWS, Civil Action--Law Plaintiff VS. DEBRA L. FAILOR, Defendant No. 03-1552 Civil Term COMPLAINT 1. Plaintiff is Teresa L. Mathews, an adult individual. 2. Defendant is Debra L. Failor, an adult individual whose last known address is 1194 Myerstown Road, Gardners, Pennsylvania, 1 7324. 3. The facts and occurrences on which this action is based took place on or about 4/5/01 in South Middleton Township, Cumberland Count, Pennsylvania, on Trindle Road, SR 0641 at the intersection with Valley Street, T-414. 4. At that time and place, Plaintiff was operating a motor vehicle eastbound on Trindle Road, SR 0641, approaching the intersection with Valley Street, T-414. 5. As Plaintiff entered the intersection, Defendant, who was operating a motor vehicle westbound on Trindle Road, SR 0641, suddenly and without warning turned left, entered Plaintiff's lane of travel, and struck the vehicle which Plaintiff was operating on the left fror~-~ie. 6. The collision described above was due entirely tcr~l~r rre~g~e~ess, and recklessness of the Defendant, which included failure to driv~ ~n~ r~ side of the highway, failing to signal a left turn, failure to yield right of way to Plaintiff, making a left turn when traffic conditions made it unsafe to do so, failure to keep a proper lookout, and operating her vehicle at an unsafe speed. 7. As the result of the collision described above, Plaintiff suffered severe and painful injuries, including cervical strain/sprain, cervicogenic migraine-like headache, sacral strain/sprain due to sacroliliac joint derangement with pelvic obliquity and rotation, pericervical myofascial syndrome, chronic pain syndrome, closed head injuw, and post traumatic stress disorder. Some or all of these injuries may be chronic or permanent. 8. As a result of her injuries described above, Plaintiff was required to seek medical a~tention and care, and has or may incur medical expenses in excess of First Party Benefit coverage. 9. AS a result of her injuries described above, Plaintiff may have suffered harm to her earning capacity. 10.As a result of her injuries described above, Plaintiff has endured great pain and suffering, and she may continue to do so indefinitely. 11 .At the time of the collision described above, Plaintiff did not own a motor vehicle, nor was she a named insured in any motor vehicle insurance policy. WHEREFORE, Plaintiff demands judgment against Defendant for damages in excess of $25,000.00, together with costs of suit, and such additional relief as the Court deems appropriate. Halt & Puhala, P.C. Attorneys for Plaintiff Fred H. Halt, ID # 34331 The Wellington 1 7 East High Street, Suite 101 Carlisle, PA 1 7013-3047 (71 7) 249-4500 249-2411 (fax) pajoblawfh@earthlink.net AFFIDAVIT I, Teresa L. Mathews, Plaintiff above named, verify that the fads set forth in this Comp/c;intare true and corred, to the best of my knowledge, information, and belief. acknowledge that an,/false statements herein are made subject to the penalties of I$ C.$. §4~04, relating to unsworn falsification to authorities. Teresa L. Mathews TERESA L. MATHEWS, Plaintiff, Vo DEBRA L. FAILOR, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 03-1552 Civil Term CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Debra L. Failor, with regard to the above-captioned matter'. Respectfully submitted, NEALON & GOVER, P.C. Andrew C. Lehman, Esquire i.D. #: 81!;)37 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this '~C"~aY of August, 2003, ~ hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Fred H. Hait, Esquire HAlT & PUHALA, P.C. 17 East High Street Suite 101 Carlisle, PA 17013-3047 Andrew C. Lehman, Esquire TERESA L. MATHEWS, Plaintiff, DEBRA L. FAILOR, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 03-1552 Civil Term CIVIL ACTION - LAW NOTICE TO PLEAD TO: Teresa L. Mathews, and her attorney, Fred H. Hait, Esquire HAlT & PUHALA, P.C. 17 East High Street Suite 101 Carlisle, PA 17013-3047 YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Date: Respectfully submitted, NEALON & GOVER, P.C. By: ~ Andrew C. Lehman, Esquire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 TERESA L. MATHEWS, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNA. : v. : NO.: 03-1552 Civil Term : DEBRA L. FAILOR, : Defendant. : CIVIL ACTION - LAW ANSWER WITH NEW MATTER 1. Admitted upon information and belief. 2. Admitted. 3.-4. Admitted. 5. Denied as stated. However, it is admitted that on April 5, 2001, the Plaintiff was traveling eastbound on Trindle Road (S.R. (141) at or near its intersection with Valley Street (T414). Plaintiff's vehicle came into contact with the vehicle being operated by Defendant, Debra L. Failor. The remaining averments contained in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). 6. Denied pursuant to Pa.R.C.P. 1029(e). 7.-11. Denied as Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter asserted, and proof is demanded at trial. Any remaining averments contained Pa.R.C.P. 1029(e). in these Paragraphs are denied pursuant to NEW MATTER 12. if set forth at length. Paragraphs 1 through 11 are incorporated Ir~erein by reference thereto as 1:3. P~aintiff's claims may be barred in whole or in part by operation and application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant respectfully requests judgment be entered in her favor and that the within Complaint be dismissed with costs as allowed by law. Respectfully submitted, NEALON & GOVFR, P.C. Andrew C. Lehman, Esquire - I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 2 VERIFICATION I, DEBRA L. FAILOR, 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: ~~_ DEBR'/~ L. FAIL~, CERTIFICATE OF SERVICE AND NOW, this ..~J~day of September, 2003, I hereby certify that I have served the foregoing ANSWER WITH NEW MATTER on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Fred H. Halt, Esquire HAlT & PUHALA, P.C. 17 East High Street Suite 101 Carlisle, PA 17013-3047 Andrew C. Lehman, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERESA L. MATHEWS, Civil Action--Law Plaintiff DEBRA L. FAILOR, Defendant No. 03-1552 Civil Term Jury Trial Demanded 13. REPLY TO NEW MATrER The allegations of Paragraph Thirteen are conclusions of law, which response. require no Respectfully submitted, Halt & Puhala, P.C. Attorneys for Plaintiff The Wellington 1 7 East High Street, Suite 101 Carlisle, PA 17013-3047 (717) 249-4500 249-2411 (fax) pajoblawfh@earthlink.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERESA L. MATHEWS, Plaintiff Civil Action--Law No. 03-1552 Civil Term DEBRA L. FAILOR, Defendant Jury Trial Demanded CERTIFICATE OF SERVICE I Certify that concurrent with filing the foregoing Reply to New Matter, I am serving a copy of same upon counsel of record for the Defendant by First Class Mail, addressed as follows: Andrew C. Lehman, Esq, Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 Date: Fred H. Halt, ID'~4331 ' - Attorney for Plaintiff Hait& Puhala, P~C. The Wellington 17 East High Street, Suite 101 Carlisle, PA 17012-3047 (717) 249-4500 249-2411 (fax) pajoblawfh@earthlink.net CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU~LNT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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 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: 12/18/2003 Attorney for DEFENDANT DEll-4G3772 3 9 O 2 5 --LO 1 LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING RBHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-24910~ 3 90 2 5--C0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR FileNo. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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 ttfings: **** SEE ATTACHED RIDER **** at The MCS Grouo. Inc.. 1601 Market Street. Suite 800. Philadeh~hia. 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 tkings 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: ANDREW C. LEHMAN, ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Dofendant Date: DEC ! 8 2OO3 Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Di~sion Deputy// EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $I00.00 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 i~ems as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diag,, o. sis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and incl.u__ding the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476614 3 9 0 2 5 --LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER 0F: TERESA L. MATHEWS COURT 0F COMMON PLEAS TERM, DEBRA L. FAILOR -¥S - CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463773 3 90 2 5 --LO 2 >>> LOCATION LIST <¢< PAGE: 1 LOCATION NAI~E RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CEIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XEAYS INS~CE DE02-249106 3 902 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR FileNo. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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: ANDREW C. LEHMAN, ESQ. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC ! 8 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil ~'ivision Deputy~ 39025-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS 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: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476616 3 9 0 2 5 --LO 2 CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSU~ TO R~E 400).22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/20'03 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463774 3 9 O 2 5 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS - COURT 0F COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF I~T~iT TO SERV~ A SUBPOHIqA TO PRODUCE DOCUMEIF~S AND FOR DISCO~,ttE PUR.gU~,NT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: FRED BAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEH~EqN, PATRICIA HOFFMAN ESQ. - 03-501 NOS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 90 2 5--CO2 LOCATION LIST <<< PAGE: i LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPEING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CASSES CHIROPRACTIC CLINIC (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 g00. 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: ANDREW C. LEHMAN. ESO. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DE(; 18 2003 BY THE COURT: Prothonotary/Clerk, Civil Di,~sion Deput~57 Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CASSES CHIROPRACTIC CLINIC 313 S. HANOVER STREET CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, histopy and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, includinlg any and all such items ~. may be stored in a computer database or otherwise in electronic mnn, re~atmg to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476618 3 9 0 2 5 --LO 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463775 3 902 5--LO4 LOCATION LIST ((¢ PAGE: I LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONNIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5--C0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILER File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BELVEDERE 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 Grouv. Inc.. 1601 Market Sweet. 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: ANDREW C. LEHMAN. Ese. 241 ! N. FRONT STREET HBRRISBURG. PA 17110 TELEPHONE: (21 ~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC f :8 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil D~vision Depq~r - EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BELVEDERE MEDICAL CENTER 850 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all .such items ,a~,. may be stored in a computer database or otherwise in electromc to .nn., re~atmg to any examination, consultation, diagnosis, care or treatment pertaunng to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476620 3 9 0 2 5 --LO 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS - CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ.' Attorney for DEFENDANT DEll-463776 3 9 O 2 5 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATEEWS DEBRA L. FAILOR -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF Ii~T~TT TO SERVE A SUBPORNA TO PRODUCE DOCUMI~ITS AND FOR DISCOV~%' L-,u.t~qI3rANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: FRED HAIT, ESQ. NCS on behalf of ANDREW C. LEHMAN, 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. DATg: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 902 5--CO 2 LOCATION LIST <<< PAGE: i LOCATION NAM~ RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5 --C02 COMMONWEALTH OF PENNSYLVANIA COUNTY-OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY 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 tkings: **** 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: ANDREW C. LEHMAN, ESQ. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (21 $) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC 1 8 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil l~vision Deputy/ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 39025 TERESA L. MATHEWS 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, fdes, memoranda, handwritten notes, histou 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: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476622 3 902 5--L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2603 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463777 3 9 O 2 5 --LO 6 >>> LOCATION LIST <<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 9025--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAL CENTER (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 Grouo. 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 tiffs 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 at~er 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: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (~15~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC 18 20O3 Seal of the Court BY THE, COURT: Prothonotary/Clerk, Civil Divi/'~on D~uty~ - ' - EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 39025 TERESA L. MATHEWS 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 m electronic form, pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476624 3 9 0 2 5 --LO 6 CERTIFICATE PRERRQUISITE TO SERVICE OF A SUBPOENA PURSUe%Y1' TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS - CASE N0: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463778 3 9 O 2 5 --LO 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. ?AILOR -VS- COURT OF COMMON PLEAS TERM, CASE N0: 03-1552 NOTICE OF ~ TO SERVE A SUBP~]%~-~ TO PRODUCE DOcuM]~qTS AND ~NGS FOR DISCO~/~Y PURSUANT TO RUL]~ 4009.21 [ Note: see enclosed list of locations ] TO: FRED HALT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREN C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 Any questions regarding this matter, contact MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 90 2 5--CO2 LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5--C0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEXANDER SPRING REHAB (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 Sweet. 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 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: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC 18 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civi~l ~{vision Oeput~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB 1 TYLER COURT CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic ~e, including but n.o.t limite, ,d to . any and all records, correspondence to and from me consmtmg ano/or treating physicians, ~es, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including a~.y ,and all .suc~ items ~a~.. may be stored in a computer .datab.a. se or o. therw~se m e~ectromc m .nn., remrmg to any examination, consultauon, dmgnos~s, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Se.c. urity #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476626 3 902 5--LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU/~'T TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT 0F COMMON PLEAS TERM, DEBRA L. FAILOR -VS - CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and thin§s pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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 sou§ht 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463779 3 9 O 2 5 --LO 8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS- COURT OF COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF I~T~ZqT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND FOR DISCO%/~x PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: FRED HAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, 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 undsrsi§ned an objection to the subpoena. If the twenty day notice period is waived or if no objectio~ is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 Any questions regarding this matter, contact MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 90 2 5--CO2 LOCATION LIST ¢<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECOP~DS & XRAYS INSURANCE DE02-249106 3 902 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NATIONWIDE INSURANCE COMPANY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN, ESQ. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC 18 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civ~l Div~on Depuff' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NATIONWIDE INSURANCE COMPANY 1000 NATIONWIDE DRIVE P. O. BOX 2655 HARRISBURG, PA 17105 RE: 39025 TERESA L. MATHEWS ADJUSTER- JOHN MCINERNEY CLAIM #58 37 C 010907 04052001 01. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all insurance records and PIP ~es, including but not limited to medical reports and/or records, cl/_ai~_s, any and all correspondence, documentation supporting plaintiff s claim, payments including dates of payments, payee. .and reasons for payments, including any and all such items as may oe storea m a computer database or otherwise in electronic form, pertaining to: ~ua. tes Requested: up to and including the present. bject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social ~.urity #: 228-06-5216 Date of Birth: 08-29-1968 Date of Loss: 04/05/2001 SU10-476628 3 9 0 2 5 --LO 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUA~IT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT 0F COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS On behalf of ANDREW C. LEHMAN, 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: 12/18/2003 · LEHMAN, ESQ. Attorney for DEFENDANT DEll-4~3772 3 9 O 2 5 --LO 1 LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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 tiffs 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: ANDREW C. LEHMAN, ESQ. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC 1 8 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Di'~sion Deputy/d/ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS 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: TERESA L. MATItEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476614 3 9 0 2 5 --LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: TERESA L. MATHEWS DEBRA L. FAILOR -VS- COURT OF COMMON PLEAS TERM, CASE NO: 03-1552 NOTIC~ OF I~T~NT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND FOR DISCO~KY PURSI]2%NT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: FRED HAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 902 5--CO2 LOCATION LIST ¢<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (Name of Person or Entity) Within twenty (20) days a~er 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 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: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC I 0 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil ~ivision Deputy~7 39025-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR 246 PARKER STREET CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATIIEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476616 3 9 0 2 5 --LO 2 CERTIFICATE PREREQUISITE T0 SERVICE 0F A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS C0URT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS - CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that {i) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463774 3 90 2 5 --LO 3 LOCATION LIST ¢<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING RERAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 90 2 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GA$SES CHIROPRACTIC CLINIC (Name of Person or Entity) Within twenty (20) days atter 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 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: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: BEC 18 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Di~sion Deput~7 - EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CASSES CHIROPRACTIC CLINIC 313 S. HANOVER STREET CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic f'fle, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwriuen notes, histou and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all .such items ~. may be stored in a computer database or otherwise in electromc mm., re~atmg to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476615 3 9 0 2 5 --LO 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU~I~T TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463775 3 90 2 5 --LO 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS - COURT 0F COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF Ilv£~NT TO SERVE A suuPOI~ ~) PRODUCE I~S AlqD FOR DISCOVERY PUP~HANT TO RUI~ 4009.21 [ Note: see enclosed list of locations ] TO: FRED HALT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) clays from the date listed below in which to file Of record and serve upon the undsrsigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATEICIA HOFFMAN - 03-501 MOS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHII~IDELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 90 2 5--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BI~LVEDERE 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 Tl~e MCS Group. Inc.. 1601 Market S~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 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: ANDREW C. LEHMAN, ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (21~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC !8 2003 BY THE COURT: Prothonotary/Clerk, Civil D~vision Dept~'- Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BELVEDERE MEDICAL CENTER 850 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items ? may be stored in a computer database or otherwise in electronic mrm, relating to any examination, consultation, diagnosis, care or treaUnent pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-475520 3 9 0 2 5 --LO 4 CgRTIFICAT~ PRERROUISITR TO SgRVICR OF A SUBPOgNA PURSUANT TO RULR 400~.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE N0: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ.' Attorney for DEFENDANT DEll-4~3776 3 9 O 2 5 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS - COURT 0F COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF IR'£~NT TO SERVE A SUBPOENA TO PRODUCE DOCUM~TTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: FRED HAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 Any questions regarding this matter, contact MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 902 5--CO2 LOCATION LIST <¢¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REEAB NATIONWIDE INSURANCE COMPANY MEDICAL RECOPJ]S X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & X~AYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 9 02 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS, DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY 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 Th~' MCS Groun. 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: ANDREW C. LEHMAN. ESO. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC ! 8 20lB Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil 19~vision Deput~/z EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten n,otes, history an~ physical reports, medication/ prescription records, nurse s notes, doctor s comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relatin$ to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476622 3 9 0 2 5 --LO 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS- CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: ~2/18/2b03 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463777 3 9 O 2 5 --LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS- COURT 0F COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF I~T~SNT TO .~R~V~ A UUB4POENA TO PRODUCE DOcuMENTS AND THINGS FOR DISCOVERY PURSUANT TO RI/f~E 4009.21 [ Note: see enclosed list of locations ] TO: FRED HAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 902 5--CO2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF IN'rl~qT TO SERV~ A SUBPOENA TO PRODUCE ~S AND THINGS FOR DISC0%/I~KY PURSUANT TO RUI~ 4009.21 [ Note: see enclosed list of locations ] TO: FRED HAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 Any questions regarding this matter, contact MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 90 2 5--CO2 LOCATION LIST <<< PAGE: i LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVSDERE MEDICAL CENTER HERSHEY MKDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-249106 3 902 5--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEXANDER SPRING REHAB (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 ATI'ACHED 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: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC 18 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil ~vision Depu~j;7 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB 1 TYLER COURT CARLISLE, PA 17013 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic frie, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, includinlg any and all such items as may be stored in a computer database or otherwase in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATItEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-476626 3 9 0 2 5 --LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBEA L. FAILOR -VS - CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 12/18/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-463779 3 9 O 2 5 --LO 8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-1552 NOTICE OF I~'£~z~IT TO SERVE A SUBPOEN~ TO PRODUCE ~S AND T~INGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: FRED HAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/28/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 Any questions regarding this matter, contact MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT THE NCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-249106 3 90 2 5--CO2 LOCATION LIST ¢<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CNTR CASSES CHIROPRACTIC CLINIC BELVEDERE MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ALEXANDER SPRING REHAB NATIONWIDE INSURANCE COMPANY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS INSURANCE DE02-24~106 3 9025--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NATIONWIDE INSURANCE COMPANY (Name of Person or Emity) WithLn 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 Grouu. 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 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: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: DEC 1 8 2003 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil DiviSion Deput'(f' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NATIONWIDE INSURANCE COMPANY 1000 NATIONWIDE DRIVE P. O. BOX 2655 HARRISBURG, PA 17105 RE: 39025 TERESA L. MATHEWS ADJUSTER- JOHN MCINERNEY CLAIM #58 37 C 010907 04052001 01. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all insurance records and PIP fries, including but not limited to medical reports and/or records, cl~,a~_ _s, any and all correspondence, documentation supporting plaintiff s claim, payme.nts including dates,o.f payments, payee and reasons for. payments, ~clud .rog .any,and ali su~cn ~tems as may be stored in a computer aata~ase or omenvlse m e~ectromc form, pertaining to: Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 PETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 Date of Loss: 04/05/2001 SU10-476625 3 9 0 2 5 --LO 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU;~ TO RULE 4009.22 IN THE MATTER OF: TERESA L. MATHEWS COURT OF COMMON PLEAS TERM, DEBRA L. FAILOR -VS - CASE NO: 03-1552 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 02/04/2004 MA~,/ESQ. ' ,; ~ ~ Attorney for DE~NDANT / ~/ DEll-471711 3 9 O 2 5 --LO 9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: TERESA L. MATHEWS DEBRA L. FAILOR -VS- COURT 0F COMMON PLEAS TERM, CASE N0: 03-1552 NOTICE OF I~'r~IT TO RRI~V~ A SUBPOENA TO PRODUCE DOCUMENTS AND T~TNGS FOR DISCov~Kf L-.uKSUANT TO RULE 4009.21 THREE SPRINGS FAMILY PRACTICE MEDICAL RECORDS & XRAYS TO: FRED HAIT, ESQ. MCS on behalf of ANDREW C. LEHMAN, 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 NCS or by contacting our local MCS office. DATE: 01/15/2004 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-501 NCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-253027 3 9 O2 5 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TERESA L. MATHEWS VS. DEBRA L. FAILOR File No. 03-1552 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THREE SPRINGS FAMILY PRACTICE (Name of Person or Entity) Within twenty (20) days alter service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at Tl~e 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 alter 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: ANDREW C. I,~I-IMAN, ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: ,/') Prothonot ary/~2-~erk, Cix~il-Div~sr~ Deputy EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THREE SPRINGS FAMILY PRACTICE 303 N. BALTIMORE AVE. MT. HOLLY SPRINGS, PA 17065 RE: 39025 TERESA L. MATHEWS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer datab~.ase or o. therwise in electro~ic fS ,._rYl oting to any examination, consultation, magnosts, care or treatment penaum~ : Dates Requested: up to and including the present. Subject: TERESA L. MATHEWS 900 pETERSBURG ROAD, CARLISLE, PA 17013 Social Security #: 228-06-5216 Date of Birth: 08-29-1968 SU10-483472 3 9 0 2 5 --LO 9 ]:N THE COURT OF COMMON PLEA,S OF CUMBERLAND COUNTY, PENN,SYLVANZA TERESA L. MATHEW,S, Plaintiff Civil Action--Law No. 03-1552 Civil Term DEBRA L. FAZLOR, Defendant ~Tury Trial Demanded PRAEC~PE TO DISCONTINUE TO THE PROTHONOTARY: Please mark this matter discontinued, settled and satisfied. Respectfully submitted, Fred Hait & Associates, P.C. Attorneys for Plaintiff The Wellington 17 East High Street, Suite 101 Carlisle., PA 17013-3047 (717) 249-4500 249-2411 (fax) pajoblawfh~earthlink.net