Loading...
HomeMy WebLinkAbout00-06394 ~ . ..l ;;,~ >:,-.,"' I. ,<'_ ,,~., 1-< ~. ,-"., _ _._. _'0, , . , '" KARON 1. LANE, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000-&391 CNIL TERM LUTHER MURPHY, JR. and KAY 1. MURPHY, Defendants CNIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ ofSununons on the above named Defendants at the following address: Luther Murphy, Jr. and Kay 1. Murphy 1002 Oriole Drive Mechanicsburg, PA 17055 t: \ ~ s,e6>I ZC/:::o Date Respectful SUBy ~ ROBERT PETER KLINE, E QUIRE 331 Bridge Street, Suite 350 Post Office Box 461 New Cumberland, P A 17070-0461 (717) 770-2540 Attomey for Plaintiff I. I Ij 1 1 I'll j ',J ." :"j j j I'J j 11 :j il iI r'J ~ I ,'j I I ~ n i ! I " WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAlNTIFF(S) HASIHAVE COMMENCED AN ACTION AGAlNST you. /5/ (!~ ,e tfl- Prothonotary If.. fI1 Date: ;;[1. 1l.)&xJ by 'ifjUa IIJ;~ Deputy II '~~, ~, ,,~ iIII '::Ili~lIItilM.JilI!! 'ilL ~...- f!! : ,,~,: U~.lJLrr,~ "~",,,J\..; -In!g",_c;~' ,,;J uJ~,"_H_\" 'r', :~!-"-,_~.l"k",,_,,, .__. _-I , ~" ", ., "',',"e_ "-,,=,,.;.-, "tF.'-, ;",;,-'~','~<"-' -.,... C/) 2: C) C. 0 " () $: en ::;:1 00 0,\ "Oee ,.., _J;-:n ~ v.~ mm -0 rl1r 1:\:::::' Z:Xl ';'tl!{ "\l - ) . .S; M~)L (;) ~L: LO (~)(i) G- d ~ .C.I,_. -.. 0 KO ",. -r""T, "'~'l - E\' ~D ::l!: S~O "--' - /.:-m 0 S~ VI G :J>c: - z C" 55 --c::. -, N ~, ~, -".->" ~ ," ~- . - .. ._~ ...."""""liltj'!,"-: " SHERIFF'S RETURN - REGULAR CASE NO: 2000-06394 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LANE KORAN L VS MURPHY LUTHER JR ET AL HAROLD J. WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon MURPHY JR LUTHER the DEFENDANT , at 1550:00 HOURS, on the 25th day of September, 2000 at 1002 ORIOLE DRIVE MECHANICSBURG, PA 17055 by handing to LUTHER MURPHY a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.82 .00 10.00 .00 34.82 .r~~~-' R. Thomas Kline 09/27/2000 ROBERT PETER KLINE Sworn and Subscribed to before By: 7~~/;{ft7 me this <5'1& day of {}~ cLo-viJ A. D. ( k, ~ 12 J-n<.t(:v <fjtPr ~ thonotary . II - ~ ~~ , il...l;-" . SHERIFF'S RETURN - REGULAR , CASE NO: 2000-06394 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LANE KORAN L VS MURPHY LUTHER JR ET AL HAROLD J. WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon MURPHY KAY L the DEFENDANT , at 1550:00 HOURS, on the 25th day of September, 2000 at 1002 ORIOLE DRIVE MECHANICSBURG, PA 17055 by handing to LUTHER MURPHY, ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So A;:~,~ R. Thomas Kline 09/27/2000 ROBERT PETER KLINE Sworn and Subscribed to before By: 7~_a~-;t;fJ /' Deputy She ff . me this ,5f!::: day of ~J.,.. .2tr?n) A.D. Ch~-';;tPon?:~:; ',~ II ) " __ ,i , OOHB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ~. ~. 1IM4i"~ . " KARON L. LANE, (PLAINTIFF) VS. LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2000-6394 CIVIL ACTION - LAw JURY TRIAL DEMANDED ENTRY OF ApPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendants, Luther Murphy, Jr. and Kay L. Murphy. Date: October 13. 2000 II Respectfully submitted, By: Girard . Rickards, Esquire Attorney for Defendants Identification No.58867 "" ,,.j ''''"', "-.Iii ! ,- '\ OOHB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a tme and correct copy of Entry of Appearance to be served by regular flIst class mail upon: Robert P. Kline, Esquire 331 Bridge Street Suite 350 P.O. Box 461 New Cumberland, PA 17070 Dated: October 13.2000 ~~ Girard E. Rickards, Esquire Attorney for Defendants II " * ootffi.oO 124 " ,.. .. '.' .. , ' , LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 11011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO TIlE PROTHONOTARY: Please enter a RULE upon Plaintiff to fIle a Complaint within twenty (20) days hereof oc _octho _ of. '_ofNooPro.. ~ ~ G' E. Rickards Esquire Date: October 13.2000 Attorney for Defendants RULE TO FILE COMPLAINT AND NOW, this .I ~y Of~' ,2000 a RULE is hereby entered upon the Plaintiff to fIle a Complaint herein within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. / D ~{(,-ad ~OOHtiYr!i:-ri '{J4 II , " # ~r ~ r ;; , -, . - '.' . -~' " - ~.- OOHB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of Defendants' Request for Production of Documents Addressed to Plaintiff to be served by regular frrst class mail upon: Robert P. Kline, Esquire 331 Bridge Street Suite 350 P.O. Box 461 New Cumberland, P A 17070 Dated: October 13. 2000 ~ ~ Girard E. Rickards, Esquire Attorney for Defendants I I ._.J o. . L~, ,---.;- r '~-'''V' J""..-. .." ! KARON 1. LANE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA i q ::1 :'j .1 v. NO. 2000-6394 ClVIL TERM LUTHER MURPHY, JR. and KAY 1. MURPHY, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED :~ tj i_; .' :' NOTICE ::j YOU HA VB BEEN SUED IN COURT.1fyou 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 wamed 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. i -:; "~I r1 I i YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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, P A 17013 (717) 249-3166 II , " , , ,I. ~~ ~~ :'.<.~ ._,. "'0, ,'"."., , ., '-'~ KARON 1. LANE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-6394 CIVIL TERM LUTHER MURPHY, JR. and KAY 1. MURPHY, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff, Karon 1. Lane, is an adult individual currently residing at 503 E. Elmwood A venue, Apt. #3, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Luther Murphy, Jr., is an adult individual currently residing at 1002 Oriole Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Defendant, Kay 1. Murphy, is an adult individual currently residing at 1002 Oriole Drive, Mechanicsburg, Cumberland County, Pennsylvania. 4. On or about September 22, 1998, Plaintiff, Karon 1. Lane, was the owner of a 1989 Oldsmobile Cutlass Sierra automobile which was involved in the accident described herein. 5. On the aforesaid date, Defendants, Luther Murphy, Jr. and Kay 1. Murphy, were the owners of a 1998 Mazda B-3000 automobile which was involved in the accident described herein. 6. On the aforesaid date, at approximately 6:00 PM, Plaintiff, Karon 1. Lane, was operating her motor vehicle in a westerly direction on Simpson Street in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, at or near the intersection of Shepherdstown Road, when her vehicle was struck in the rear by the Defendants' motor vehicle which was being operated by Defendant Luther Murphy, Jr. in a westerly direction on Simpson Street behind and in the same lane as Plaintiff Karon 1. Lane's vehicle. 7. At the time of the accident herein described, Plaintiff Karon 1. Lane was lawfully II - ,- ~ -'r-- .. "",'- '" ~^ ^' ."~ -, stopped, with her left turn signal activated, while waiting to make a lefthand turn onto I' Ii , Shepherdstown Road. 8. The accident was directly and proximately caused by the negligence and carelessness of Defendant Luther 1. Murphy, Ir., which consisted, among other things, of the following: A) Operating his motor vehicle in a careless, reckless, and negligent manner; B) Operating his motor vehicle at an excessive rate of speed under the circumstances; C) Operating his motor vehicle with no warning of approach or intended direction; D) Not having his motor vehicle under proper control so as to stop said vehicle within the assured clear distance ahead (75 Pa.C.S. g3361); E) Operating his motor vehicle without due regard to the rights, safety, and position of the Plaintiff; F) Failing to have his motor vehicle under the proper control so as to prevent this vehicle from striking the Plaintiff's motor vehicle; G) Failing to keep a proper lookout; H) Failing to use due care under the circumstances; 1) Failing to notice the motor vehicle of the Plaintiff; J) Upon noticing the motor vehicle of the Plaintiff, failing to yield the right-of-way to Plaintiff's vehicle; K) Failing to take evasive action in order to avoid impacting with Plaintiff's vehicle; L) Failing to apply his brakes in sufficient time to avoid striking Plaintiff's stationary car; M) Operating his motor vehicle in disregard of the rules of the road, the ordinances of the Borough of Mechanics burg, and the laws of the Commonwealth of Pennsylvania, including but not limited to the Motor Vehicle Code, 75 Pa.C.S. g3361 and 3362. 9. At all times material hereto, Plaintiff, Karon 1. Lane, acted with due care and was not contributorily negligent. 10. As a result of the Defendant's negligence, Plaintiff, Karon 1. Lane, sustained the following injuries, some or all of which may be permanent: A) Cervical thoracic strain and lumbar strain, with resulting pain to her neck and right shoulder; B) Post-traumatic headaches; II -,- -L- ~~ ' = ' ",,"1,' '~ ,. -_~ ~* C) Temporomantibular joint dysfunction (TMJ), resulting in severe and pennanent pain and discomfort in her jaw and resulting headaches and other ongoing problems; and D) General bruises and contusions. j, 11. As a result of Defendant's negligence, Plaintiff, Karon 1. Lane, has suffered great bodily pain and suffering, as well as mental anxiety and nervousness, to her great detriment and loss. 12. As a result of the Defendant's negligence, Plaintiff, Karon 1. Lane, has sustained serious and permanent injury, for the treatment of which she has incurred medical bills and expenses, and for which she will require continuing and ongoing treatment in the future. 13. As a result of the Defendant's negligence, Plaintiff, Karon 1. Lane, has suffered an interruption of her daily habits and pursuits to her great and permanent detriment and loss. 14. Plaintiff has made demand for compensation of the aforesaid injuries and losses, which Defendants have failed and refused, and still refuses, to pay. WHEREFORE, Plaintiff, Karon 1. Lane, demands judgment in her favor and against Defendants in an amount in excess of Twenty-Five Thousand and 00/100 ($25,000.00) Dollars, exclusive of interest and costs. tfully submitted, 14 M.enJ ? ~ Date ROBERT P TER KLINE, 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff II ,. ,.- "" ' " . VERIFICATION I verifY that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authoriiies. _I ( / ~ / V1J Date \ KARON L~ LANE II '-~--"" i :~ '-._ - __, '"ow ". , .~ CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing Complaint upon Defendant by depositing same in the United States Mail, first class, postage pre-paid on the 14th day of November, 2000, from New Cumberland, Pennsylvania, addressed as follows: Girard E. Rickards, Esquire Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, P A 17011 Attorney for Defendants c ~~<:>>'n , ROBERTPi:;rTh~SQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff II ~~.w....,..iiIt'""""-- .~~ .!l' ":lil,t1ii";L 1-- (") C z uCG mr,' 2:3:-1 ?Q'~; ~C; :J> -, Zb ;pC 2:: ::2 L-:> o z 8 ~r,-- -.- 'I I ~~ -1'"1 ~ ,,:- ~~j i;'~ (~~ ~71 -=-.:\ do :..( -0 "e. ....1 l.' " CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 11/16/2000 As on b~ .~~ ,Ie GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DEll-219246 43170-LOl II COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE KATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY. JR.. ET AL - MURPHY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TODD L. SAKOELS. M.D. DR. ALEXANDER KALENAK ROBERT J. BEAUDRY. JR.. M.D. MEDICAL MEDICAL MEDICAL TO. ROBERT PETER KLUtE. ESQUIRE MCS on behalf of GIRARD 11:. RICKARDS. ESQUIRE 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 ot by contacting our local MCS office. DATE. 10/27/2000 MCS on behalf of GIRARD E. RICKARDS. ESQUIRE Attorney for DEF'EIlDA8T CC. GIRARD E. RIClCAllDS. ESQUIRE - 00HB-00124 DARLA HAHP'l'Oa - 5837B194015 Any questions regarding this matter. contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-135964 43:1. 7 0 - C 0 :I. II _ _..' " "",.! COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KARON L. LANE -AUTO VS LUTHER MURPHY. JR., ET AL -MURPHY FileNo. 2000-6394 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 . TO: CUSTODIAN OF RECORDS FOR: TODD L. SAMUELS, M.D. (Name of Penon or Entity) Within twenty (20) days after servke of this subpoe"""you are ordered by the court to produce the following documents or things: SEE ATTACHED . at MCS GROUP INC.. 1601 MARKET ST., 1/800, PHILA. ,PA 19103 ' (Adclrns) 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 servke, 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: GIRARD E. RICKARDS. ESQUIRE 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT Illk ATTORNEY FOR: THE DEFENDANT NAME: ADDRESS: BY THE COURT: DATE: 11/16/2000 Prothonolaly/CIerk. Civil Division Deputy Seal of the Court (Eff. 7/97) I I " ' L . ~ 11 '.$!' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TODD 1. SAMUELS, M.D. 890 POPLAR CHURCH ROAD SUITE 107 CAMP HILL, PA 17011 RE: 43170 KARON 1. LANE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. LANE " 503 EAST ELMWOOD AVENUE, MECHANICSBURG, PA 17055 Social Security #: 182-46-4507 Date of Birth: 04-21-1954 5UlO-273818 43 l7 0 - L 0 l II " ",-, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE certifies. that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/16/2000 GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DEl1-219247 43170-L02 II , L ~~ . - '~'f-"'. ., CO~ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COllRT OF COMMON PLEAS KAROH L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LlJTIIh. MURPHY. JR., ET AI. - KtlRPHY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THIMGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TODD L. SAMUELS, H.D. DR. A LIlY ANDER ICALENAll: ROBERT .J. BEAUDRY. JR., M.D. KEDICAL MEDICAL MEDICAL TO: ROBERT PETER KLIliE, ESQUIIlE MCS on behalf of GIB.AlID E. RICKARDS, ESQUIIlE 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: 10/27/2000 MCS on behalf of GIB.AlID E. RICKARDS, ESQUIIlE Attorney for DEFENDANT CC: GIB.AlID E. RICUlIDS, ESQUIIlE DARLA IIAHP'fOlI' - 00BB-00124 - 5837B194015 Any questions regarding this matter. contact THE MCS GROUP INe. 1601 HARKET STREET #800 PBILADKLPBIA, PA 19103 (215) 246-0900 DE02-135964 43170-COl II " ' q^ , -- """",-. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KARON L. LANE -AUTO VS LUTHER MURPHY, JR., ET AL -MURPHY File No. 2000-6394 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 . TO: CUSTODIAN OF RECORDS FOR: DR. ALEXANDER KALENAK (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 u MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Ad"""") You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to thtl 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: GIRARD E. RICKARDS, ESQUIRE ADDRESS: 21:4 SENATE AVENUE. SUITE 503 CAMP HILL, PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT Inlt ATTORNEY FOR: THE DEFENDANT BY THE COURT: DATE: 11/16/2000 PtothonolalyfClerk,. Civil D1vllion Deputy Seal of the Court (Eff. 7/97) II ".. . . - '" ,1 .ilIaH' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR.ALEXANDERKALENAK 875 POPLAR CHURCH RD CAMP HILL, PA 17011 RE: 43170 KARON 1. LANE Any and all records, correspondlence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. lANE 503 EAST ELMWOOD AVENUE, MECHANICSBURG. PA 17055 Social Security /I: 182-46-4507 Date of Birth: 04-21.1954 SUlO-273820 43170-L02 II ~~" - 6-' """" , ~1t: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -vs- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE certifies that (1) A notice of intent to serve the. subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is, identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/16/2000 GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DEll-219248 43170-L03 II . .,~ <- ;.'.- CO~ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND III THE MATTER OF: COURT OF COMMOH PLEAS KAROH L. l.AHB - AUTO TERM, -VS- CASE HO: 2000-6394 LUTHER MURPHY, .JR., ET AL - MURPHY NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THIMGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TODD L. SMmELS, M.D. DR. ALEXAlmER KALEHAK ROBERT .J. BEAUDRY. .JR., M.D. MEDICAL MEDICAL MEDICAL TO: ROBERTPETEII. KLINE, ESQUIRE KCS on behalf of GIRARD E. RICRARDS, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fram 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 KCS ot by contacting our local KCS office. DATE: 10/27/2000 MeS on behalf of GIRARD E. RICRARDS,.. ESQUIRE Attorney for DIttEHDAHT CC: GI1IARD E. UClWlDS. ESQUIU DARLA IWII'ftHt' 00HB-00124 - 5837B194015 Any questions regarding this matter, contact THE MCS GROUP IHC. 1601 HARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-135964 431. 7 0 - C 0 1. II ~-~ .'. ~~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KARON L. LANE -AUTO VS LUTHER MURPHY, JR., ET AL .,.MURPHY F'1 N 2000-6394 1 e o. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 . TO: CUSTODIAN OF RECORDS FOR: ROBERT J. BEAUDRY, JR., M. D. (Name of Penon 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 ~CS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Ad_' You may deliver or mail legible copies of the documents or pn>cIuce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the adclresslisted above. You have the right to seek, in advance, the reasonable cost of preparing the copies or produdng 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: GIRARD E. RICRARDS, ESQUIRE ADDRESS: 214 -SENATE AVENUE. SUTTE ~Ol CAMP HILL, PA 17011 TELEPHONE: 21 ~-246-0900 SUPREME COURT IUft.- ATIORNEY FORlHE DEFENDANT BY THE COURT: DATE: 11/16/2000 Prothonotary/Clerk. Civil Division Deputy Seal of the Com (Eff. 7/0/7) .1 . j -. ' '~'"fij; EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROBERT J. BEAUDRY, JR., M.D. 3600 OLD GETTYSBURG ROAD CAMP HILL, P A 17011 RE: 43170 KARON 1. LANE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. IANE 503 EAST ELMWOOD AVENUE, MECHANICSBURG, PA 17055 Social Security #: 182-46-4507 Date of Birth: 04-21-1954 SU10-273822 43170-L03 II llillJllIWlIkMilUllt' l"~i!l~iiGti"02,."',"iIV"'~",""!.~'<Il~M~lU""W,~I""'.'~L,,,,,,,,lt,",,,,,,!~~.,.""~,,,,_.,,J,~;'!!-"-;,",;~iilt{'lIll$!.W"'_~II/jlii~gr,li>' ~-~ ,,~<:lLJIJ.J:i>tJ]!~ IJIliiL. ~_'MI"""'U'e' ,. h ' -iiiJ~^[jr5li!1f1~1lIoW~_ll<IieiI o c ? ll;';'~: c0h-;' 2f2~ fg~~ ~~r~: )>c ;;:::- -; -< I -r:~ C,) ~ E:5 '- ~, r...:) () -r-; , ,-, 'I~': .'r,l .,I~) c- ~' "" co .., . . ~ 1~~~ .- OOHB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CuMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAw JURY TRIAL DEMANDED NOTICE YOU HA VB 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 Answer with New Matter of Defendants Luther MUlJ?hy. Jr. and Kay L. MUlJ?hy to Plaintiff's 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 Answer with New Matter of Defendants Luther Mu:mhy. Jr. and Kay 1. MUlJ?hy to Plaintiff's 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 TInS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 I I '''""'''WJ: OOHB-00124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAw JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANTS LUTHER MURPHY, JR. AND KAY L. MURPHY TO PLAINTIFF'S COMPLAINT AND NOW, come the Defendants, Luther Murphy, Jr. and Kay L. Murphy, by and through their attorney, Girard E. Rickards, Esquire, in support of Answer with New Matter of Defendants Luther Murphy, Jr. and Kay L. Murphy to Plaintiff's Complaint hereby avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. I I ~ n,(illlit;t;, 6. Admitted. 7. Admitted. 8. The averments in paragraph 8 constitute a conclusion oflaw to which no response is required. To the extent that a response is deemed required, each and every averment of paragraph 8 is specifically denied and strict proof thereof is demanded at the time of trial. 9. The averments in paragraph 9 constitute a conclusion of law to which no response is required. To the extent that a response is deemed required, each and every averment of paragraph 9 is specifically denied and strict proof thereof is demanded at the time of trial. 10. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 10. Therefore, each and every averment of paragraph 10 is specifically denied and strict proof thereof is demanded at the time of trial. 11. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 11. Therefore, each and every averment of paragraph 11 is specifically denied and strict proof thereof is demanded at the time of trial. 12. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 12. Therefore, each and every averment of paragraph 12 is specifically denied and strict proof thereof is demanded at the time of trial. 13. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 13. Therefore, each and every averment of paragraph 13 is specifically denied and strict proof thereof is demanded at the time of trial. 2 ,I ,-".,,-._' , iMliii.:-, 14. Afterreasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 14. Therefore, each and every averment of paragraph 14 is specifically denied and strict proof thereofis demanded at the time of trial. WHEREFORE, Defendants Luther Murphy, Jr. and Kay 1. Murphy respectfully request your Honorable Court to Dismiss the Plaintiff s Complaint with prejudice. NEW MATTER 15. The Plaintiff's claims for non pecuniary damages may be barred by the limited tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act. 16. The Plaintiff's claims for medical expenses and! or wage loss are barred, or should be reduced pursuant to ~ 1722 of the Pennsylvania Motor Vehicle Financial Responsibility Act. 17. The Plaintiff has failed to state a claim upon which relief may be granted against Defendant Kay 1. Murphy. WHEREFORE, Defendants Luther Murphy, Jr. and Kay L. Murphy respectfully request your Honorable Court to dismiss the Plaintiff's Complaint with prejudice. Respectfully submitted, Date: December 12. 2000 By: OF JACOBS & SABA irard E. Rickards, Esquire Attorney for Defendants Identification No. 58867 3 I I OOHB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAW JURY TRIAL DEMANDED VERIFICA TION We, Luther ~~rphy, Jr. and Kay L. Murphy, verify that the statements made in the foregoing Answer with New Matter of Defendants Luther MUJ;phy. Jr. and Kay L. MU1l!hy to Plaintiff's Complaint are true and correct to the best of my knowledge, information and belief. I understand that false stateme,nts herein are made subject to the penalties of Pa.C.S.A. ~4904, relating to unsworn falsification to authorities. ;."1 - 7 DO Dated: ^ - ~~!4- " Luther Murphy, Jr., Defenllant Dated: I~ - '7 -00 ~ ~ PJ~ . Kay L. Murphy, dant I I .~ ~ - < ' ~--~j OOHB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of Answer with New Matter of Defendants Luther Mm;phy. Jr. and Kay L. MUI;phy to Plaintiff's Complaint to be served by regular fIrst class mail upon: Robert P. Kline, Esquire 331 Bridge Street Suite 350 P.O. Box 461 New Cumberland, P A 17070 Dated: December 12. 2000 ~ ~ Girard E. Rickards, Esquire Attorney for Defendants I I " ~'--'" . .'"' ~ "=",-,' - ,,,,,-., .~ ,~. " "'-"'-~'--'-';';":" -,~'- '-' ,'-:t-',' ;....,.-,' KARON 1. LANE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-6394 CNIL TERM LUTHER MURPHY, JR., CNIL ACTION - LAW JURY TRIAL DEMANDED Defendant ANSWER TO NEW MATTER 15. Denied. On the contrary, Plaintiff is fully entitled to her claims for non-pecuniary damages as she had, at the time of the accident, elected the full tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act. 16. The allegations of this paragraph are a legal conclusion to which no responsive pleading is required. To the extent that a response is required, the allegation is denied. 17. The allegation of this paragraph is a legal conclusion to which no responsive pleading is required. However, the parties have entered into a Stipulation, which shall be filed of record, which removes Kay 1. Murphy as a defendant in this action. Respectfu11y submitted, 2. S.p..N: '2..00 \ Date c-~_ ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, P A 17070-0461 (717) 770-2540 Attomey for Plaintiff I I ~-",. -'". , , .. ,~.' ,"",-,".' ,,,i,) " -~ --.,- , I , ,.. -,,' , "< , VERIFICATION I, Robert P. Kline, Esquire, attomey for the Plaintiff herein, have sufficient knowledge of the facts contained in this Answer to New Matter and verify that the statements made in the foregoing Answer to New Matter are true and correct to the best of my knowledge, based upon information received from the Plaintiff. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. A verification executed by the Plaintiff will be filed of record as soon as it becomes available. c-)~~. z.. (fA1'-\- '2- CJc) \ Date ROBERT P. KLINE, ESQUIRE II .,', ,. ,--,"--'" ,-, "',__ _b'_~ . ',v." , c- "':', -,- ,-.,._r ;-,,-';'-,,,,<~_.- ~,-~~--- , -. CERTIFICATE OF SERVICE I hereby certifY that I served a true and correct copy of the foregoing Answer to New Matter upon Defendant by depositing same in the United States Mail, first class, postage pre-paid on the 2..1A-J day of January, 2001, from New Cumberland, Pennsylvania, addressed as follows: Girard E. Rickards, Esquire Law Offices of Jacobs & Saba 214 Senate Avenue, Suite 503 CampHill,PA 17011 Attorney for Defendant ROBERT PETER KL 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff I I " ~" c' _" L ,;;""'.~,~~- '-, '~, " - -",-,"" - :iili~...."i -,"-=- '~~ ,),I,dd,~! ~IU"III)i.JUllllI.U!!ll.ll""bk." .1llTUUJl!m.ul.., 'u,' "....,.. .' ;<" ., o 5;:: "';:- "tJG-: Ill,,--" Z-.._~.1 ~__ ._/1 .c,. C0,.---o> ~(~: ,.;;:-C: ~c::: .2: ::;I , ~ '" ,"- ':11 fu Q C) "--- :r::r.. ..;.:: ~~:1 'b ."". ~ ~ " ,; i , ,,_.-t~ ,. \ I OOHB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 903 Camp Hill, P A 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAYL. MURPHY, (DEFENDANTS) CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW, this .J.:). Nt{y of llA N WtIC-Y ,2001, upon consideration of the attached Stipulation of Counsel, it is hereby ordered and directed that the Defendant, Kay L. Murphy, be dismissed as a party in this action. It is further ordered that . ?J'O\ t~O\'} ~ the caption be revised as noted in the attached Stipulation of Counsel. J. I I Jt ,,1' - """' ". .. I ' . , I~" ~'~~~~ .-. ~_JfIU.._... ._~~Rm'_i''f'101!''1''''-'9>"''~''II'11l~'1~'~!'''''~~Il'IlOll1I'~~l!MW~~~ ~-. -- J-" 'k-_'_~ "~'_"<""'.'._~_-_ .~__-, ,'_ '_">'_="_"~'_ " FiLED-QfFlCE OF THE pp01HONOTARY 01 JAW 22 PM 2:55 CUMBERLAND COUNlY PENNSYLVANIA ... l , OORB-OO 124 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, P A 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAvL. MURPHY, (DEFENDANTS) CIVIL ACTION - LAw JURY TRIAL DEMANDED STIPULATION OF COUNSEL It is hereby stipulated by the parties herein that the Defendant, Kay L. Mutphy, be dismissed as a party to this action. It is further stipulated that the caption in this matter be revised as follows: Karon L. Lane, Plaintiff In the Court of Common Pleas Cumberland County, Pennsylvania vs. No. 2000 - 6394 Luther MtL.'j)hy, Jr., Defendant Civil Action - Law Jury Trial Demanded ~f)~o- Robert Peter Kline, Esquire Kline Law Office 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070 Attorney for Plaintiff Court I.D.5'R19 R ~ Law Offices of Jacobs & Saba 214 Senate Avenue Suite 503 Camp Hill, PA 17011 Attorney for Defendants Court LD. 58867 Date: I a l) ~ z,,:rYJ Date:_1 /11. I () I / I I I < . ,~ i:::/iil' .f'fI 'l' OOHB-OOl24 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp HilI, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CuMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR. AND KAY L. MURPHY, (DEFENDANTS) CIVIL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of Stipulation to be served by regular fIrst class mail upon: Robert P. Kline, Esquire 331 Bridge Street Suite 350 P.O. Box 461 New Cumberland, P A 17070 Dated: January 16. 2001 d E. Rickards, Esquire Attorney for Defendants I I "t: ~ ~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 02/21/2001 ~~ . GIRARD E. RI~KARDS. ESQUIRE Attorney for DEFENDANT DEll-236578 43170-L04 I I I, , I .. , ^, 'It', , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SPORTING HILL FAMILY HEALTH MEDICAL TO: ROBERT PETER KLllIE. ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/01/2001 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEl'ENDANT CC: GIRARD E. RICKARDS, ESQUIRE DARLA HAMPTON - 00HB-00124 - 5837B194015 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144091 43170-COl I I ~.. '.' dli , COMMONWEAL 1H OF PENNSYLVANIA - COUNT!' OF CUMBERL\...'\'D KARON L.LANE -AUTO VS FileNo. 2000-6394 LUTHER MURPHY, JR., ET AL -MURPHY SUBPOENA TO PRODUCE DOCUMTh-rS OR THINGS FOR DISCOVERY PURSUAJI,;-r TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: SPORTING HILL FAMILY HEALTH CENTER (Name of Penon or Entity) \Vithin ro.-.oenry' (20) days after service of this subpoena. you are ordered by th~ court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Address) You may del;,'er or mail legible copi... 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 ha\'e the right to seek, in ad,'ance.tho r..sonable cost of prepanng the copies or producing the things sought. If you fail to ;r.oduce the documents or things required by this subpoena. ,..;t!".in twenty PO) da)'s after its sen'ice. the party serving this subpoena may seek a court order compelling you to comply with ;+_ THIS SlillPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: !\:AME: (;TRARD E. RTCKARDS. ESOUIRE ADDRESS: 214 SENATE AVE~, SUITE 503 CAMP HILL, PA 17011 TELEPHO~E: 215-246-0900 SUPREME COURT ID #: ATIOR.'\EY FOR; n"""MnANT DATE: ,J2A) ;;(9, 2/"")0 { '--- Prolhonotary/o~~ v' Ion ~n..-1. 0 P.. cn/W"LJ Depu Seal of the Court (Eff, 7/97) I I " '", ~ ~'-':',; , EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SPORTING HILL FAMILY HEALTH 350 SPORTING HILL ROAD MECHANICSBURG, PA 17055 RE: 43170 KARON 1. LANE INCLUDING REPORTS Any and all records, correspondence, fIles and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. LANE . 503 EAST ELMWOOD AVENUE, MECHANICSBURG, PA 17055 Social Security #: 182-46-4507 Date of Birth: 04-21-1954 SUlO-288460 43:L 7 0 -LO 4 I I ~i1!~~.$Il;,".;,1"'<"d"_,",''';'iliB'k;llilLbII>~~!"""",~'1"J1jH"''''''-"",.:1t1"~"'3",..Ic@i,",'-'1::,-,J.i'-i"4"':-'<'''i'&,"''''''I''''>4li!t__i>>''~_~~-~~ .!l1~1I11 '"-~ " C.-._',,,,","" '..."'.. ." '<0 ~= 0. 2:~i 65~': ~;;;: ,-- '-- k'-~' /' . i:E~ ,- ~ ~- .... , o () "f< .." n (-:"'1 C0 Q ~ ~y ~~ '" " , " '-"'''-' ( CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 05/08/2001 'Y;;:,n~~ej'lf Of~ ~I~R~~I~RDS, ESQUIRE Attorney for DEFENDANT J~. DEll-250407 43170-LOS , I .......... ". I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DAVID S. ZIMMERMAN, K.D. MEDICAL TO: ROBERT PETER KLINE, ESQUIRE KCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 KCS office. DATE: 04/16/2001 '" Kes on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT CC: GIRARD E. RICKARDS, ESQUIRE DARLA HAMPTON - 00HB-00124 - 5837B194015 Any questions regarding this matter, contact THE KCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l50148 43170-COl I I ~~ '-~"iJ:.'_' , COMMONVVEAL TH OF PENNSYLVANIA - COUNTY OF CUMBERLA...'l'D KARON L. LANE -VS- File No. 7000-6194 LUTHER MURPHY, JR. & KAY L. MURPHY SUBPOENA TO PRODUCE DOCUMTh,.s OR THINGS FOR DISCOVERY PURSUA."" TO RULE 4009.12 TO: CUSTODIAN OF RECORDS FOR: DAVID ZIMMERMAN, M.D. ' (~.ame o( Penon or Entity) Witkin .......e:r.y 120) days after service of this subpoena. you are ordered by the court to produce the following documents or tkings: ~F.F. ATTACHED . 1601 MARKET STREET SUITE 800 PHILADELPHIA, PA 191U3 al THE MCS GROUP INC. \ A<lclrft.\ You may d.in.... or mail legible copies of the documents or produce things requested by this subpoena. togetk.r wilk the c.rtificat. of compliance. to tk. party making this request at the address listed above. You have the right to seek. in ad\'lnc.. tho ,"uonable cost of preparing the copies or producing the things Sought. If you fail te ;rooduce the documents or things requirtd bv IhillUbpoeN. wit.':in twenty (~) c:a~'s aft.r its ser\'ic.. the party s'I'\'ing this su.poena may seek a court order compellins you to comply with;o_ THIS SL llPOENA WAS ISSUED AT THE REQt:UT Of THE FOLLOWING PERSON: NAME: GIRARD E. RICKARDS, ESQUIR!: ADDRESS: 214 SENATE AVE. SUIT! ~) CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT 10 ,: AITOR.'\E"t' FOR: DEFENDANT DATE: Jlpn ; l It) ;;).1"')01 [ ~~~..;- -ac;n.o_P ~y,/ Seal of the Court :"f i/9l I I ~ " ~ " , EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID S. ZIMMERMAN, M.D. 6 MARKET PLAZA WAY FAMILY INTERNAL MED MECHANICSBURG, PA 17055 RE: 43170 KARON 1. LANE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. IANE 503 EAST ELMWOOD AVENUE, MECHANICSBURG, PA 17055 Social Security H: 182-46-4507 Date of Birth: 04-21-1954 ,.., 5UIO-300166 43 l7 0 - I. () .~ i I Jill~~i'i~";- .' 0: ~~~MiiJ"'!"'';N\~'''.&''~;''J.j";",lli;m"",d.-';l~,,,,,,,,,,,,,,~,..~__...llIli'>!I!5i1iil11!..tl,'I. ~~< , ~" .'~ , ' .~,' ~ > h.~,.l" - lldl-oll \ (") C) .. c: , ~~ _7" -C c';-' ;t:.'-'" ..~. " m rr , -, , r'"-~ Z ::-:p .- " , T"! Z r' ~ ") ,~ (J) ~t:~, ..;:'- '-r" -< "~) , ' r:: c.~' :-=1 .~..' ~ -0 - ::,i--i () -;;;... S;:.: jo~ CJ l5 !::6 C 7; .,- :;! =< ~J eJl -< , I - ~ '~ "!"Jf ~-,i . . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 06/07/2001 A;CS on ~~ of ' ~C. -~.'-.<,,-, GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DEll-257825 43170-L06 . I 1., " '..1 .....;: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND tN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR.. ET AL - MURPHY NOTICE OF Ilfl'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMBR'I.'S AND THI$GS FOR DISCOVERY PURSUANT TO RULE 4009.21 KEITH P. FISHER, D.D.S. JOBl!l S. KAUFFAMN, D.D.S. MEDICAL MEDICAL TO: ROBERT PETER KLDlE, ESQUIRE KeS on behalf of GIllARD E. RICKAIlDS, ESQUIRE 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 KeS or by contacting our local KeS office. DATE: 05{18/2001 KCS on behalf of GIllARD E. RICKAIlDS, ESQUIRE Attorney for DEFEIl])ART CC: GIllARD E. RICKARDS, ESQUIRE DARLA BAKPTOR - 00HB-00124 - 5837B194015 Any questions regarding this matter, contact THE KeS GROUP IRe. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-153395 431. 70-C01. II -. . .' ., L -~ COMMOl'lWEAL TH OF PENNSyt VANIA ' COUNTY OF CUMBERLA..'iD KARON 1. LANE VS File~o. 2000-6394 LUTHER MURPHY,JR & KAY L.MURPHY SUBPOENA TO PRODUCE DOCUM~"'TS OR THINGS FOR DISCOVERY PURSUA.""'T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: KEITH P. FISHER, D.D.S. (S..me of Pfl"!On or :nary) Wi,hin rw''''Y 1::Il) days Utu ,.,,'j.. of this ,ubpoeno. you .... ord.red by the C'O..rt to prod.... the fallowing do...m.nts or 'hings: SEE ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 1.~d~'1 at You ma~' d.u""r or maill.gible .opi.. of the doo..m.ntt or prod.... thinp req....ted by this ,..bpoena. tag.th.r with the ,"rtifk". 0: <ampll~n... to the pany lIIaking this r.qu..t at the .ddnss listed abon. Yo.. have the right to ,..1<. in adn"... th. :'tuonabl. <ost of preparing the .opi.. or prod...;ns the thinp _ght. If yo.. flil.ta Toadu..the doo..ments or thingsrequir.d bv this subpoeN. within twenty (:!O) "ays Ut.r its ",,'k.. .h. PUlY ,."'ing titis '~"poena may seek a.ourt order .0mp.lli"s \'0" to ,olllply with r_ THIS St"BPOENA WAS ISSUED AT THE REQt."ESTOFTHE FOLLOWING PERSON: :'\AME: GIRARD E.RICKAIlDS,ESQ. .4.DDRESS: ? 1 b. ~RNATR A~ ~TF. C;01 CAMP HILL, FA 17011 TELEPHO:'\:: 7.1 <;-246-0900 S1,;PRE.\fE COUaT 10 .: ATIOR.'\E"t. FOR: DEFENDANT DATE: fY1 'd Y I~. 2nt1 I , Se.1 of the Court (:off i/97) II , ~ J '" t """''''"ll>.fj EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KEITH P. FISHER, D.D.S. 1001 SOUTH MARKET STREET MECHANICSBURG, PA 17055 RE: 43170 KARON L. LANE INCLUDE ANY AND ALL DENTAL RECORDS. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. LANE 503 EAST ELMWOOD AVENUE, MECHANICSBURG, PA 17055 Social Security #: 182-46-4507 Date of Birth: 04-21-1954 5UlO-306368 43170-L06 , I " , L ""'"ii, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTIlER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 06/07/2001 GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DEll-257826 43170-L07 II , "t " , '-""--'-, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -vs- CASE NO: 2000-6394 LUTHER MUaPHY, JR., ET AL - MURPHY NOTICE OF Il'ITENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THI"GS FOR DISCOVERY PURSUANT TO RULE 4009.21 KEITH P. FISHER, D.D.S. JOHN S. KAUFFAHN, D.D.S. MEDICAL MEDICAL TO: ROBERT PETER KLINE, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 KCS or by contacting our local MCS office. DATE: 05/18/2001 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT CC: GIRARD E. RICKARDS, ESQUIRE - 00HB-00124 DARLA HAMPTON - 5837B194015 Any questions regarding this matter, contact THE KCS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-153395 43 :L 7 0 - C O:L - ," '"~-~,C!!l'_"," COMMOf\.IWEAL TH OF PENNSyt VANIA . COUNTY OF CUMBERLA.'iD KARON L.LANE VS File~o. 2000-6394 LUTHER MURPHY,JR & KAY L.MURPHY SUBPOENA TO PRODUCE DOCUM~"'TS OR THI:-.lGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: JOHN S. KAUFFMAN, D .:D. 5 (S.amr of Penon or Enary) \\'ithin rw.~'I::Il) days aft.r servi.. of titis subpoeno. you .... ord.red by the C'O..rt to prod.... the fallowing da...m.nts or 'hings: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (.~ddtft'l Yo.. ma~' deu...r or maill.gibl. copies of th. dooum."tt or prod.... thinp requested by this subpoena. tog.th.r with Ih. ,"rtifkat. 0: <amplia".e. to the party IIIwng this r.quest at the addnss listed abov.. Yo.. haveth. right to ,..1<. i" ad",,,... the :'tuonable cost of preparing th. .opies or prod...ing the thinp _ghl. If you fail Ie ?"o"u,' the do...ments or things required by tltis ,ubpoeN. within twenty (:!O) "ays aft.r its ,.n'i.e, the PUlY '."'ing titis l~"po.n. may seek a .owt order .0mp.i1ing yo.. to <olllply with r_ THIS SL"BPOENA WAS ISSUED AT THE REQl:EST OF THE FOLLOWING PERSON: SAME: GIRARD E.RICKARDS,ESQ. ADDRESS: ? 1 L.. ~F.NATF. AV"'R ~TF. ':;0':\ CAMP HILL, PA 17011 TElEPHOS:: 71 <;-746-0900 S1,;PREME COlrRT 10 .: A1!OR.'\EY FOR: DEFENDANT B Oep1aty DATE: (Yl~y J L ;)..()() I . Seal of the Court (:o:f ilg7) I I ., , ,. i~: EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN S. KAUFFAMN, D.D.S. 222 SOUTH MARKET STREET MECHANICSBURG, PA 17055 RE: 43170 KARON L. LANE INCLUDE ANY AND ALL DENTAL RECORDS. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. LANE 503 EAST ELMWOOD AVENUE, MECHANICSBURG, PA 17055 Social Security #: 182-46-4567 Date of Birth: 04-21-1954 SUlO-306370 43:L 70 - L 07 I I , -iilbll~'_~~~~""~<lIlW>''''''J':';'''''!i!I;",~.~''-illiilig;i&j,,,,,,J,:~.:~:\~mllliil''''.'".".f' ,~,JJl1ILJLJb~~_ ".. "",.._, ''-' ~~.~_ ~~'"" ," , .;+. .",,' -, >< -~- ."' ~~., .= ~_" M~ ~, '., ~~~~ - .. ~.~ "-' - I 0 C> ,., c.: --n ;s: '- _r~J "'0 0:' c:: ~~1i~ rnrn z Z:"D -o'~; zr- -;J', m~_: OC) .:..(?- CO ;po =2 :+\ '=- :1: -~~.?~ eej 20 - ~c - 0 -I 2: :..> 1; :;! a> -~ w ... CERTIFICATE .. PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 07/24/2001 ~S o~:!/y ~f . ~E.~QUIRE Attorney for DEFENDANT DEll-268055 43170-LOa '",i, ~ Vo<' '.", ".H,",~" , COMMONWEALTH OF PENNSYLVANIA .. COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KARON L. LANE - AUTO TERM, -VS- CASE NO: 2000-6394 LUTHER MURPHY, JR., ET AL - MURPHY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 STEVEN FISHER, M.D. MEDICAL TO: ROBERT PETER KLINE. ESQUIRE HCS on behalf of GIRARD E. RICKARDS. ESQUIRE 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 HCS or by contacting our local HCS office. DATE: 07/02/2001 HCS on behalf of GIRARD E. RICKARDS. ESQUIRE Attorney for DEFENDANT CC: GIRARD E. RICKARDS, ESQUIRE DARLA IlAMPTOR - 00HB-00124 - 5837B194015 Any questions regarding this matter, contact THE MCS GROUP IRC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-157867 43:L 7 0 - C O:L " .' '.' ". " , .. COMMONVVEAL TH OF PENNSYLVANIA . COUNTY OF CUMBERlASD KARON L.LANE -AUTO VS File No. 2000-6394 LUTHER MURPHY, JR., ET AL -MURPHY SUBPOENA TO PRODUCE DOCUMThL'S OR THI~GS FOR DISCOVERY PURSUA.I\L' TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:DR. STEVEN FISHER (N,amf of Person or Enet:!..) ""Oithin f'\i\.oe~' (20) days after service at this subpoena~ you are ordered by the murt to produce the folJowing documents or things: ~~~ A 1'1' ACHRD MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Addr...) a. You may "e~er or mail legible copies of the dooume"ts or prod..ce things req..ested by this subpoena, together with the ..rtiCkat. 0: <amplian.e, to the puty lIIaking this req..est at the address listed above. Yo.. ha\'ethe right to ,eel<. i" ad"an.e, the :'tuonable cost of preparing the .apies or produdng the thinp _ght. If you f&il to Toadu.e the do<..ments or things required by this subpoen.a. ",;tr.in twenty (20) "ays after its ,el'\'i<., the puty ,e,,'ing titis s~"poen. may seek a .0\Ut order .0mpeIling you to <olllply with r_ THIS SL"BPOENA WAS ISSUED AT THE REQUEST OFlHE FOLLOWING PERSON: :-;AME: GIRARD E. RICKARDS, ESQ. 214 SENATE AVE., STE 503 ADDRESS: CAMP HILL. PA 17011 TElEPHO:-;E: 215-246-0900 SUPREME COtJRT ID #: ATIOR.'\EY FOR: DEFENDANT DATE: ..... )1.1 A ) r:' d P. d../)(J I , Se.1 of the Court (:Off. i /97) ""L' ,..., . - ""'J ,e EXPlANATION OF REQUIRED RECORDS ... TO: CUSTODIAN OF RECORDS FOR: STEVEN FISHER, M.D. 395 ST. JOHN'S CHURCH RD. CAMPHILL" P A RE: 43170 KARON L. LANE INCLUDING DENTAL RECORDS. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KARON L. LANE 503 EAST ELMWOOD AVENUE, MECHANlCSBURG, PA 17055 Social Security #: Jl82-46-4507 Date of Birth: 04-21-1954 5U10-314288 43170-L08 II ,I~- , - ~~.:-'- ~ I .~ .l."L ,_" - .~ . \ , OOHB-OO 124 KLINE LAW OFFICE Robert P. Kline, Esquire 714 Bridge Street P.O. Box 461 New Cumberland, PA 17070 Attorne s for Plaintiff KARON L. LANE, (PLAINTIFF) IN THE COURT OF COMMON PLEAS CuMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-6394 LUTHER MURPHY, JR., (DEFENDANT) CIVIL ACTION - LAw JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. KIlNE LAW OFFICE Date: I' .:1 A No 200 z.. B~V~ Robert p, Kline, Esquire 714 Bridge Street P,O, Box 461 New Cumberland, PA 17070 Attorney for Plaintiff CourtI.D. 5l:>'1'ct.e, I I ---"~"""""-~*~Miiti,w<_~~:'_~ tLc:U:Uc L,L.,,,,,.I!,,,,...,,,,,,,, It .,'~ ",-'q".~"-,,, ,".,- "" -'1..-'''' ....."'~'"""L~ "'--, " _~" ~"""" _ o c " [pe~ zl:---- U),,0;: -<: .,..;:. ~S .;>c. z; ~ - , . C) r",j '--='." c.~ ~~, ~, :::> tJi ,.,< 4" ~~