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Home My WebLink About00-06887 -I~ -~ f'Mi~,.i SHELLER. LUDWIG & BADEY BY: Jamie. L. Sheller, Esquire lOEtmFICAnoNHO. AnoRNEYFOR Plaintiff 152B WALNllT STREET . 3RD FLOOR PHILADELPHIA. PENNSYLVANIA "102 12151541-5510 CHRISTINE PARR 137 Winston Drive Mechanicsburg,PA 17055 COURT OF COMMON jPLEAS CUMBERLAND COUN1~Y vs. KEYSTONE SPINE CENTER, INC. 1521 Cedar Cliff Drive Camp Hill, PA 17011 and RUSSELL F. POOLE, P.T. 1521 Cedar Cliff Drive Camp Hill, PA 17011 No.OQ- (PIP? C'PC-Mq, ! :1 ii i " '1 II NOTICE You have bMn sllMf in eoun..t you wish to d.f~ -clainat'dle daim. set 'ann in en. fOllowing pag... YOU ""'It Ilk. KIion wilhin rwentY 120' dey. a"lf mi. comDlain. Ind notice are """H. by "Iering a' 'Nriaen 'appeer.,a p.raonelly Or by enomey end filing in wrlling widl'lI'Ie coun vo:. ...... or obiKdON 'bI1M deirn. Nt fO(tt'I ag~., you. You... '""'" , cnet: if you f8il to do 10 the,-=-- """ proceed without you end a jucIgmont ..... bo _._ VOU by .... ...".._ fu".,., nat:ice for illy money dailMl!t in the c:omilIlint: 01 for any other deim or ,.., recaunt:ed by Ih., DleinliH. You may 10_ mon.y or ~ or orIMr righu im""1m IO~. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER DR CANNOT AFFOAD ONE. GO TO OR TELEPHONE THE OFFICE SET FOATH BELOW TO FIND DUT WHEAE YDU CAN GET LEGAL HELP. Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 AVISO Le ,h.. dllmMdedo a u... en Ie con.. Si' ....d quiere de'encHr. de ..t.. d.....nQs 'XDU",II. en .a. ,...... sigWentn.. ua1_ tirtn. win. .,~f). diU. .>de. ..-. ..' .' ....." .,.!1ir.. de I. fectae de I. dtrlftMde y .. notificeciOn., H_, ,. ....., una com.........,o. eKrit* o,en ~,..,n.'o'ci~un-~.,YlentreQ... . .. carte en forme -.criIa-.,' _~,~,o:_~:;1i~;j>~~-h;. ,'a .........., ~a:d.IU:~ $t":~"".-"'" no H dafHinde., Ii' ,COI"N tom...8 ~:y-':-~:~ Ie demendil en contra IllY. 'fin' pteVio avi_ 0 ~. Adem... la carte pUedIt 'deddir, ,a favor del, ~ y teQuillre que u~ c:umPf. con' tOdu ... af~' de uta dim""'. Uated, ~ Perd., dinero 0 .... p~_f1 u otto. deNCho. imDO~!D," uated. ,. . u.!VEESTA.O~.liDA A UliAaOQADOI~EOIAiTENTE. 51 NO T1. E. NE ABDc:lXDOOSl'NOTlEli". iEt.,O. !1!\l....EJlO ..' i*"....,..'1!NTE DE PAGAA TAL SERVIClO. VA YAEN'MSO'l'IJi,O, . 'i. ..E PaR TEUFONO A LA.OFICINA CUYA QIRECCiOIi:SEEI'!' .EIITRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASIST<NClA LEGAL 717-249-3166 1.1 --'--, ,,-..',-- I I.;.,....,;, . " ,1 ~ i' " <' .'-,,_, ,.-;.;.i~_ SHELLER, LUDWIG & BADEY By: Jamie L. Sheller, Esquire Identification No. 55722 1528 Walnut Street - Third Floor Philadelphia, PA 19102 215-790-7300 Attorney for Plaintiff CHRISTINE PARR 137 Winston Drive Mechanicsburg, PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. KEYSTONE SPINE CENTER, INC. 1521 Cedar Cliff Drive Camp Hill, PA 17011 TERM, 2000 and RUSSELL F. POOLE, P.T. 1521 Cedar Cliff Drive Camp Hill, PA 17011 NO. tHl- c,if1 ~ ~ COMPLAINT 1. Plaintiff, Christine Parr is an adult individual residing at the above address. 2. Defendant, Keystone Spine Center, Inc. (hereinafter referred to as "Defendant, Center") is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania with an office for service of process at the above-captioned address. At all times pertinent hereto, Defendant Center acted by and through its agents, servants, workmen and/or employees acting in the course and scope of their duty to the said plaintiff. 3. Defendant, Russell F. Poole (hereinafter "Defendant Poole") is an adult individual who at all relevant times was engaged in the practice of physical therapy, maintaining an office at the LAW OFFICES SHELLER, LUDWIG & BAOEY JIisl..d,1 ''L IJ.JIU I ri);:'"" ,c,_,-,,,"I ~.~ _ J., ,~ 'O_IML; above noted address. 4. At 'all relevant times, defendants acted by and through their agents, servants, workers and/or employees acting in the course and scope of their duties to said plaintiff. 5. At all relevant times, Defendant, Poole was the agent, servant, worker and/or employee, of Defendant Center, acting in the course and scope of his duties to said plaintiff. 6. On or about September of 1998 Ms. Parr suffered a minor injury to her back while moving a television set to remove some wallpaper in her home. 7. An MRI scan performed on October 12, 1998 found minimal degenerative changes at 14-5, no focal disc herniation or focal stenosis and mild subligamentous disc protrusion at 14-5 and at L5-S1 without disc extrusion. 8. The plaintiff first attended therapy at the Defendant Center on or about October 21, 1998. 9. She continued with therapy at Defendant Center on October 23,1998, October 27, 1998, and on November 4, 1998. 10. On or about November 6, 1998 plaintiff once again attended therapy at Defendant Center however at this visit Defendant, Poole performed a maneuver in which he severely injured plaintiff's back. I I. On or about November 9, 1998 the plaintiff once again returned to Defendant Center in which she reported that after her last visit to the center her back was extremely sore in the low and center area and she began to have pain shooting down her leg for the first time and was having trouble walking and standing. 12. Defendant Center scheduled another visit for Ms. Parr on November I I, 1998 but she was unable to ever return to therapy at Defendant Center again. LAW OFFICES SHEllER, LUOWfG & BAOEY ,..1,., ,'^, '-.' ~'. . ., , "< 13. An MRI taken on or about November 27, 1998 indicated that plaintiff now had a disc herniation laterally at L3-4. As a result of said condition plaintiff has been forced to undergo numerous surgeries as well as other medical treatment and therapy in an attempt to correct the injury to her back. COUNT I PLAINTIFF v. DEFENDANT POOLE 14. Plaintiff incorporates paragraphs 1 through 13 as fully set forth herein at length. 15. Defendant negligently and carelessly fuiled to adhere to standards of medical care in the following respects: ( a) failing to properly perform physical therapy procedures; (b) failing to properly evaluate plaintiff's condition prior to performing physical therapy procedures; (c) failing to properly assess plaintiff's physical condition in order to determine what physical therapy procedures could be safely administered; (d) failing to adequately stabilize plaintiff prior to performing physical therapy maneuvers; and (e) failing to safely and properly perform physical therapy maneuvers. 16. As a direct and proximate result of the negligence and carelessness of Defendant Poole jointly and/or severally, plaintiffhas suffered and will continue to suffer serious and permanent damage to her body and organs including herniation of the discs in her back, necessitating subsequent medical tests, treatment, procedures, surgeries, and other damages. 17. As a direct and proximate result of the negligence and carelessness of Defendant, ~ LAW OFFICES SHELLER, LUDWIG & BADEY ."..-' "",~ ~ow~:. L,I.I 1-'", ',""_' >, _ c.I~" ~, .,,---~--- --~~ Poole jointly and/or severally, plaintiffhas experienced and will experience a loss of wages, inability to perform her duties and hobbies, and a loss of enjoyment of life. 18. As a direct and proximate result ofthe negligence and carelessness of Defendant Poole, jointly and/or severally plaintiff has paid and will pay substantial medical bills. 19. As a direct and proximate result ofthe negligence and carelessness of Defendant Poole, jointly and/or severally, plaintiff has experienced and will experience pain and suffering, emotional distress, and embarrassment and disfigurement. WHEREFORE, plaintiff respectfully requests judgment in her favor and damages in excess of $50,000.00 plus costs, attorneys fees, and other relief. COUNT II PLAINTIFF v. DEFENDANT. CENTER 20. Plaintiff incorporates by reference paragraphs 1 through 19 as though fully set forth herein at length. 21. Defendant, Center negligently and carelessly failed to adhere to the standards of medical care in the following respects: (a) failing to ensure plaintiff's safety and well-being while at Defendant Center; (b) fuiling to use reasonable care in the maintenance of safe and adequate facilities; (c) fuiling to have in place proper protocol to insure plaintiff was properly evaluated and treated prior to discharge from Defendant Center's care; (d) failing to properly train its staff and provide them with proper rules, regulations, and other protocol in order to fully evaluate and treat plaintiff; ( e) fuiling to oversee all persons who practice physical therapy medicine within LAW OFFICES SHELLER, LUDWIG & BADEY .,' ~- I,., ~iMl Defendant, Center as to patient care; and (f) fulling to formulate, adopt, and enforce adequate rules and policies to ensure quality care. 22. As a direct and proximate result of the negligence and carelessness of Defendant Center jointly and/or severally, plaintiff has suffered and will continue to suffer serious and permanent damage to her body and organs including herniation of the discs in her back, necessitating subsequent medical tests, treatment, procedures, surgeries, and other damages. 23. As a direct and proximate result of the negligence and carelessness of Defendant, Center jointly and/or severally, plaintiffhas experienced and will experience a loss of wages, inability to perform her duties and hobbies, and a loss of enjoyment of life. 24. As a direct and proximate result of the negligence and carelessness of Defendant Center, jointly and/or severally plaintiffhas paid and will pay substantial medical bills. 25. As a direct and proximate result ofthe negligence and carelessness of Defendant Center, jointly and/or severally, plaintiff has experienced and will experience pain and suffering, emotional distress, and embarrassment and disfigurement. WHEREFORE, plaintiff respectfully requests judgment in her favor and damages in excess of$50,000.00 plus costs, attorneys fees, and other relief. SHELLER, LUDWIG & BADEY E L. SHELLER, ESQUIRE Attorney for Plaintiff LAW OFFICES SHELLER, LUDWIG & BADEY [I , -,-,. I , 'r.'-I--., ~." '.-1 ,--"-'-'--'. ,___iLi~ , " .........".h: . . VERiFiCATiON The undersigned, having read the attached Complaint, verifies that the within Complaint is based on information furnished to counsel which information has been gathered by counsel in the course of the within lawsuit. The language of the Complaint is that of counsel and not of signer. Signer verifies that she has read the within Complaint and that the factual averments are true and correct to the best of signer's knowledge, information and belief. To the extent that the contents of the Complaint are that of counsel and/or legal terminology, verifier has relied upon counsel in taking this verification. It is und~rstood that the statements therein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. r 25hooo DAIrE ekt~/aMJ CHRiSTiNE PARR LAW OFFICES SHELLER, LUDWIG & BADEY " .lIiliJ ~ . - - .", '~j'iJJ.@~~~~'-'- >' ~:::~il~MMllI '-rllll- 'n~~~~ fJ 70* \k~ -- i"- <> " tv Gf} () G' \) ( ....~....~ ~. ~ ""~"-.-,, IflI 'i 15>\ -CQ. ~ ~~ 8 8 a I ~r ~ -.z:- ; ;...;;~ "-.''n--_;,c;.,'<,-, _ o c :e: ~.~~ (,':l",> ~..<:'" yC) ~ ?-:~ 5c :~ g .C:::) ,") :-1 I IT> s:~ -;;J.'...; " "'0 ~- ~-~;'" ,'~> :.1." :.:::~=~ ~~,~f. ~. :b :-<: ,:- ., o ...1 -~- no\ 8 ~ ,- ,,--,,^------ ~ .. '~.t IiI;;U ,~ _ I L J, ~- ~!!l~lR,', . SHERIFF'S RETURN - REGULAR CASE NO: 2000-06887 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARR CHRISTINE VS KEYSTONE SPINE CENTER INC CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KEYSTONE SPINE CENTER INC the DEFENDANT , at 0010:24 HOURS, on the 16th day of October 2000 at 1521 CEDAR CLIFF DRIVE CAMP HILL, PA 17011 by handing to LISA KEENER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.68 .00 10.00 .00 36.68 So Answers: r.'~~.<~.t R. Thomas Kllne . Sworn and Subscribed to before 10/17/2000 SHELLER, LUDWIG & BADEY ~~ By: ;;Z. < . .' / De ty Sheri me this .:l3M..... day of CD~ ~crv-U A.D. ~Q~~ rothonotary , ~ "t ~L.~._< ~ _ _.L l ~..J I ~.~~o: . SHERIFF'S RETURN - REGULAR CASE NO: 2000-06887 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARR CHRISTINE VS KEYSTONE SPINE CENTER INC CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland county,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon POOLE RUSSELL F, P.T. the DEFENDANT , at 0010:24 HOURS, on the 16th day of October ,2000 at 1521 CEDAR CLIFF DRIVE CAMP HILL, PA 17011 by handing to L I SA KEENER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: rK-4t!~~t R. Thomas Kline Sworn and Subscribed to before 10/17/2000 SHELL::: LUDWIGf:~; ~ ;; ;;~j s~eL;f me this ,;/3 ""J day of - CD rl"iJ.... d<.-1lVCJ A . D . C1A' () 'n/J !-e"I.J, ~. P othonotary T ,1- , .,-",[ - ,--~- SHELLER, LUDWIG & BADEY By: Jamie L. Sheller, Esquire Identification No. 55722 1528 Walnut Street - Third Floor Philadelphia, PA 19102 215-790-7300 - ,~ I _::- ':~~~" Attorney for Plaintiff CHRISTINE PARR vs. KEYSTONE SPINE CENTER, INC. and RUSSELL F. POOLE, P.T. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL TERM NO. 00-6887 PROOF OF SERVICE OF COMPLAINT AND NOTICE BY SHERIFF OR DEPUTY SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA UPON DEFENDANTS, REYSTONE SPINE CENTER, INC. AND RUSSELL F. POOLE, P.T. DATED: October 23. 2000 SHELLER, ..--- / BY~~ IE L. SHELLER, SQUIRE Attorney for Plaintiff LAW OFFICES SHELLER, LUDWIG & BADEY -.::\1-~ b.... ~ ~ I ~ .". ..'-',,~g,,-'. SHERIFF'S RETURN - REGULAR ./ CASE NO: 2000-06887 P c COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARR CHRISTINE VS KEYSTONE SPINE CENTER INC CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KEYSTONE SPINE CENTER INC the DEFENDANT , at 0010:24 HOURS, on the 16th day of October ,2000 at 1521 CEDAR CLIFF DRIVE CAMP HILL, PA 17011 by handing.to LISA KEENER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.68 .00 10.00 .00 36.68 So Answers: ~~~~{:4( R. Thomas Kline me this day of 10/17/2000 SHELLER, L~ & BAD:/~ By: ,}. < . .' / ~Sheri . Sworn and Subscribed to before A.D. Prothonotary . I ~ "_iil*,~ilkj":,_,, SHERIFF'S RETURN - REGULAR CASE NO: 2000-06887 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARR CHRISTINE VS KEYSTONE SPINE CENTER INC CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon POOLE RUSSELL F, P.T. the DEFENDANT , at 0010:24 HOURS, on the 16th day of October ,2000 at 1521 CEDAR CLIFF DRIVE CAMP HILL, PA 17011 by handing to LISA KEENER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: .r~e.-<~~ R. Thomas Kline me this day of 10/17/2000 SHELL::: LUDW~~::;J 1Ig: f ;;9tti shet.f Sworn and Subscribed to before A.D. Prothonotary ~-!~"-~ I,.... ""~"." "c-~'iJi(~ .I 1_-, _ I, ~ _ --' J. ,__ _, _,,__ ~ """"""'"''''''''Po: , ' IOl_18\LIAB\JCFlLLPGI158951\LXLI03125\00999 MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: JOHN C. FARRELL, ESQUIRE Identification No.: 52824 1845 Walnut Street, 18th Floor Philadelphia, PA 19103 (215) 575-2787 Attorney for: Defendant CHRISTINE PARR : COURT OF COMMON PLEAS : CUMBERLAND COUNTY v. KEYSTONE SPINE CENTER, INC. and RUSSELL F. POOLE, P.T. : NO. 00-6887 ENTRY OF APPEARANCE JURY TRIAL DEMANDED FEE PERFECTED TO THE PROTHONOTARY: Kindly enter my appearance on behalf of defendants, Keystone Spine Center, Inc. and Russell F. Poole, P.T. in the above-captioned matter. MARSHALL, DENNEHEY, WARNER, COLEMAN AND GOGGIN BY: 1 . ARRELL, ESQUIRE tt or: Defendants, Keystone Spine Center, Inc. and Russell F. Poole, P.T. "",i~I"''''iiJ"","_~~'_'~ -" " ~ J 1_. -- '-~~~'~~_illill.,J"",,,,~,r;i~bi"'1,'!>>t""""a"'"'''''''',k, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: JOHN C. FARRELL, ESQUIRE Identification No.: 52824 BY: KENNETH S. FAIR, ESQUIRE Identification No.: 68982 1845 Walnut Street, 18th Floor Philadelphia, PA 19103 (215) 575-2787 ro.fl4l..w:f~ (",,*,J/ YOU AIlE H!.'RE6'.'''01!~I~'- r~' I'ltA; TO >>iE I!NC!.O$W~ '''IN.!I!!tJ,.It.. Wtll11N ~TY (20) " i';:, H~C)M. flU SfRVlQ HEREOf . OR ".\ ()~F A1.Jn Attorneys for Defendants ~ MA~ lIE fNir(j/fl) AGAINil Keystone Spine Center, Inc.~OU;, / r- and Russell F. Poole, P.T. _-' ~ I-- , ~loUr lOIl-b~~ - .. CHRISTINE PARR COURT OF COMMON PLEAS CUMBERLAND COUNTY v. KEYSTONE SPINE CENTER, INC. and RUSSELL F. POOLE, P.T. : NO. 00-6887 ANSWER OF DEFENDANTS, KEYSTONE SPINE CENTER, INC. AND RUSSELL F. POOLE. P.T. TO THE COMPLAINT OF PLAINTIFF CHRl:STINE PARR Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T. by and through their attorneys, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN, hereby Answers the complaint of the plaintiff, Christine Parr, as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Denied. As stated. It is admitted that the plaintiff, Christine Parr gave a history of back symptoms that were present since September 15, 1998. 7. Denied. After reasonable investigation, answering defendants are without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of plaintiffs complaint and strict proof thereof is demanded at time of trial. .. ,i'.."....."""'. --- . , '~~,J ~~1'#~ 8. Admitted. 9. Admitted. 10. Denied. It is admitted only that on November 6, 1998 the plaintiff, Christine Parr attended therapy with defendant, Russell F. Poole, P.T., at Keystone Spine Center, Inc. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc. or Russell F. Poole, caused or contributed to any alleged injuries, losses or damages to the plaintiff, Christine Parr. 11. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., were not negligent. It is admitted that on November 9, 1998 the plaintiff, Christine Parr reported increasing soreness into the low back which was worse with standing and walking. Ms. Parr previously reported constant back, thigh and knee symptoms since September 15, 1998 that were exacerbated with prolonged walking. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., caused or contributed to any alleged injuries, losses or damages to the plaintiff, Christine Parr. 12. Denied as stated. It is admitted that the plaintiff, Christine Parr was last treated on November 9,1998. She was scheduled for a subsequent visit on November 11, 1998 arid Ms. Parr called on that day to cancel and she never returned. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. .;,i1l1i1l<WiOl ,I~ """'""...........""""'--"'~ ~ .~" I I~ , 1"~c... n -'''!'lfW.:c Poole, P. T. caused or contributed to any alleged injuries, losses or damages to the plaintiff, Christine Parr. 13. Denied. After reasonable investigation, answering defendants are without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of plaintiffs complaint and strict proof thereof is demanded at time of trial. By way of further response, defendants, Russell F. Poole, P.T., and Keystone' Spine Center, Inc. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T. caused or contributed to any alleged injuries, losses or damages to the plaintiff, Christine Parr. COUNT I PLAINTIFF v. DEFENDANT RUSSELL F. POOLE. P.T. 14. Answering defendants incorporates by reference their answers to paragraphs 1 through 13 inclusive as though fully set forth at length herein. 15. Denied. Defendant, Russell F. Poole, P.T., was neither negligent nor careless. All treatment rendered by defendant, Russell F. Poole, P.T., fully and completely complied with the standard of care. In addition, by way of further response, defendant, Russell F. Poole, PT., asserts the following: (a) He properly performed physical therapy in accordance with the standard of care; (b) He properly evaluated Ms. Parr's condition prior to performing physical therapy procedures; (c) He properly assessed plaintiffs physical condition to determine what physical therapy procedures could be safely administered; (d) He adequately stabilized the plaintiff prior to performing physical therapy maneuvers; '.,,",Ii:i_"_~ ~~ I ~ ................... [~ '''''''',;; (e) He safely and properly performed all physical therapy maneuvers. 16. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., were neither negligent nor careless. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., is caused or contributed any alleged injuries, losses or damages to the plaintiff, Christine Parr. 17. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, PT., were neither negligent nor careless. All treatment rendered by Defendants, Keystone Spine Center, Inc., and Russell F. Poole, PT., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., has caused or contributed to any alleged loss of wages, inability to perform duties and hobbies and loss of enjoyment of life to the plaintiff, Christine Parr. 18. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., were neither negligent nor careless. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. No act omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., has caused the plaintiff, Christine Parr to incur medical bills and expenses in the past, present or future. 19. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, PT., were neither negligent nor careless. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. ",""'"...... ~,~ ~~ ,.1... ~~~ ",I "","-. - -"-" ~1Im,miJ No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., has caused or contributed to any alleged loss of wages, inability to perform duties and hobbies and loss of enjoyment of life to the plaintiff, Christine Parr. WHEREFORE, for the foregoing reasons, defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., respectfully request that judgment be entered in their favor and that the Complaint be dismissed with prejudice together with costs of suit, counsel fees, and such other and further relief as this Court may deem to be just and proper under the circumstances. COUNT II PLAINTIFF v. DEFENDANT. KEYSTONE SPINE CENTER. INC. 20. Answering defendants incorporates by reference their answers to paragraphs 1 through 19 inclusive as though fully set forth at length herein. 21. Denied. Defendant, Keystone Spine Center, Inc. was neither negligent nor careless. All treatment rendered by defendant, Keystone Spine Center, Inc. fully and completely complied with the.standard of care. No act or omission by defendant, Keystone Spine Center, Inc.. caused or contributed to any alleged injuries, losses or damages to the plaintiff, Christine Parr. In addition, by way of further response, defendant, Keystone Spine Center, Inc., asserts the following: (a) Defendant insured plaintiffs safety and well being; (b) Defendant used reasonable care in the maintenance of safe and adequate facilities; (c) Defendant had in place proper protocols to ensure plaintiff was properly evaluated and treated prior to discharge; ~o,., .J~_, .1 ._L -~ .I.. ~.'-' lil'i'~~ (d) Defendant properly trained its staff and provided them with proper rules, regulations and other protocol in order to fully evaluate and treat the plaintiff; (e) Defendant properly oversaw all persons who practiced physical therapy medicine at the facility; (f) Defendant properly formulated, adopted and enforced adequate rules and policies to ensure quality care. 22. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T. were neither negligent nor careless. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., is caused or contributed any alleged injuries, losses or damages to the plaintiff, Christine Parr. 23. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., were neither negligent nor careless. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, PT., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., has caused or contributed to any alleged loss of wages, inability to perform duties and hobbies and loss of enjoyment of life to the plaintiff, Christine Parr in the past, present or future. 24. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., were neither negligent nor careless. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. ,'1J ,~--, ... . '~~ No act omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., has caused the plaintiff, Christine Parr to incur medical bills and expenses in the past, present or future. 25. Denied. Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., were neither negligent nor careless. All treatment rendered by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., fully and completely complied with the standard of care. No act or omission by defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., has caused or contributed any alleged injuries, losses or damages to the plaintiff, Christine Parr. WHEREFORE, for the foregoing reasons, defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., respectfully request that judgment be entered in their favor and that the Complaint be dismissed with prejudice together with costs of suit, counsel fees, and such other and further relief as this Court may deem to be just and proper under the circumstances. NEW MATTER 26. Any acts or omissions which plaintiff alleges to constitute negligence were not the substantial cause or substantial factors and did not result in the injuries or losses alleged by plaintiff. 27. The negligent acts or omissions of other individuals may have constituted the superseding causes of the damages and injuries alleged to have been sustained by the plaintiff. 28. The complaint and plaintiffs alleged cause of action are barred by the Statute of Limitations. 29. The plaintiffs claim and alleged causes of action are barred in whole or in part by the Pennsylvania Health Care Malpractice Act. ~"-~~-- ."~ ~ . - - .~. ~"-~""-411i1i!_,i 30. The plaintiff may have signed a Release which would act to release all claims against answering defendants. 31. Plaintiffs complaint fails to state a cause of action for damages. 32. Plaintiffs injuries, if any, were caused by the negligence of others over whom the defendants had no control and whose conduct the defendants had no reason to anticipate. 33. The plaintiffs claim and/or alleged causes of action are barred and/or must be reduced pursuant to the Pennsylvania Comparative Negligence Act. 34. The plaintiff may have been contributorily negligent. 35. The plaintiff may have assumed the risk. 36. Any treatment provided by the defendants was not the proximate cause or contributing factor of the alleged injuries suffered by the plaintiff. 37. Any and all care and treatment provided by defendants was in accordance with the standard of care set forth within the medical community. WHEREFORE, for the foregoing reasons, defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., respectfully request that judgment be entered in their favor and that the Complaint be dismissed with prejudice together with costs of suit, counsel fees, and such other and further relief as this Court may deem to be just and proper under the circumstances MARSHALL, DE COLEMAN & G , WARNER BY: ARRELL, SQUIRE KE H S. FAIR, ESQUIRE Attorney for Defendants, Keystone Spine Center, Inc. and Russell F. Poole, P.T. 101 18\LIABIKSFILLPGl1593201DAH\03125100999 , ;,;~."' '" ~ ~ I ~ ~~ "~' -~ . ... . '" .~, "'"'''Iii, CERTIFICATION OF SERVICE I hereby certifY that I have served upon all persons listed below a true and correct copy of Answer to complaint in the above-captioned matter this date by regular mail. Jamie 1. Sheller, Esquire Sheller, Ludwig & Badey 1528 Walnut Street, 3rd Floor Philadelphia, PA 19102 Respectfully submitted, MARSHALL,DENNEHEY COLEMAN AND GOG BY: John C. F Kenneth S. Ir, Esquire Attorney for Defendants, Keystone Spine Center, Inc. and Russell F. Poole, P.T. DATED: !~----g--ou 101_18\LIAB\KS~LPGI159320IDAH\03125100999 "" . ~ ~.- J "~ ,;.,~~ "'"~=m"i . . VERIFICATION The undersigned, Russell F. Poole, P.T., having read the attached Answer of Defendants, Keystone Spine Center, Inc., and Russell F. Poole, P.T., hereby verifies that it is based on information furnished to counsel, which information has been gathered by counsel in the course of this lawsuit. The language of the Defendants' Answer to Plaintiffs Complaint is that of counsel and not of signer. Signer verifies that he has read the within pleading and that it is true and correct to the best of signer's knowledge, information and belief. To the extent that the contents of the pleading are that of counsel, verifier has relied upon counsel in taking this verification. This verification is made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsifications to authorities. C2Jt(](;d ?t Russell F. Poole, P.T. DATE:..N.t:lIL 16\ lQx) 9 lliltoii-.. "'i~ _O'lll-- , ''"''[I' ~- ., -, -~ -- ~" ,,-~ 1- . 'l ;' lir mii-1 - t.. ~ """~'--"""~=t~ ,-I. ~ ,,~ ." ~ ,". ~, , ii;tl " ...... - ~, -~ - ",- ' ...:.. ~ ~~ , ---,~.. :!l!~M&Wl]i~" ,',", 0 0 C) C 0 " -~ C;) ;,:,::1 :::.:'" -OeD rY1 i:; i ~:TI rilrn n ZTI ~-'~'1 \;9 ~~~= ~_CJ -0 ~~ ~(') ::l!: =1::::> td c"5m pi::: j;! :z '-:1 "'"' ::D .-<; -< -~ , "-, ~" >, ~. .>..~-,-- . , i i r- I,' , r' 'I' . (,I ! I .-1.: ',_;,~___ ~:-,,:---~L. -- "","" ^,'~'_;;.' ,,~ ~~'~If: SHELLER, LUDWIG & BADEY By: Jamie 1. Sheller, Esquire Identification No. 55722 1528 Walnut Street - Third Floor Philadelphia, PA 19102 215-790-7300 Attorney for Plaintiff CHRISTINE PARR COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. KEYSTONE SPINE CENTER, INC. and RUSSELLF. POOLE, P.T. CNIL TERM NO. 00-6887 NOTICE TO PLEAD You are hereby notified to plead to the enclosed Reply of Plaintiff, Christine Parr to New Matter of Defendants, Keystone Spine Center, Inc. and Russell F. Poole, P.T. SHELLER, LUD, ADEY ~ By: JAMIE 1. SHELLER, ESQ Attorney for Plaintiff LAW OFFICES SHELLER, LUDWIG & BADEY .. ~ll '1"'- I , '~. -'---0" '."" . ~-'---.-- '" ~""->'~; SHELLER, LUDWIG & BADEY By: Jamie 1. Sheller, Esquire Identification No. 55722 1528 Walnut Street - Third Floor Philadelphia, PA 19102 215-790-7300 Attorney for Plaintiff CHRISTINE PARR COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. KEYSTONE SPINE CENTER, INC. and RUSSELLF. POOLE, P.T. CIVlL TERM NO. 00-6887 REPLY OF PLAINTIFF, CHRISTINE PARR, TO NEW MATTER OF DEFENDANTS, KEYSTONE SPINE CENTER, INC. AND RUSSELL F. POOLE, P.T. 26. Denied. The allegations contained in paragraph 26 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. To the extent that said allegations may be considered factual in nature, which assertion is specifically denied, after reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of said allegations; wherefore, the same are likewise denied and strict proof thereof is demanded at the time of trial. 27. Denied. The allegations contained in paragraph 27 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict LAW OFFICES SHELLER. LUDWIG & BADEY ~ ~ >[ . ,,'+- - - "':'- ,- ~ " l",' 0'--'_--0 url-lilliii~: proof thereof is demanded at the time of trial. To the extent that said allegations may be considered factual in nature, which assertion is specifically denied, after reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of said allegations; wherefore, the same are likewise denied and strict proof thereof is demanded at the time of trial. 28. Denied. The allegations contained in paragraph 28 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at time of trial. By way of further response, however, it is specifically denied that plaintiffs claims are barred in any respect by the applicable statute of limitations. 29. Denied. The allegations contained in paragraph 29 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. 30. Denied. The allegations contained in paragraph 30 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. To the extent that said allegations may be considered factual in nature, which assertion is specifically denied, after reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of said allegations; wherefore, the same are likewise denied and strict proof thereof is demanded at the time of trial. 31. Denied. The allegations contained in paragraph 31 of Answering Defendants' New I LAW OFFICES SHELLER, LUDWIG & BADEY ,"- '-ie,"~ '. "-I '--",,' , '.~li: Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. By way of further response, however, it is specifically denied that Plaintiffs Complaint fails to state a cause of action upon which relief can be granted. 32. Denied. The allegations contained in paragraph 32 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. To the extent that said allegations may be considered factual in nature, which assertion is specifically denied, after reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of said allegations; wherefore, the same are likewise denied and strict proof thereof is demanded at the time of trial. 33. Denied. The allegations contained in paragraph 33 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. By way of further response, however, it is specifically denied that plaintiffs claims are barred in any respect by the Pennsylvania Comparative Negligence Law. To the contrary, plaintiff was not negligent. 34. Denied. The allegations contained in paragraph 34 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. By way of further response, however, it is II II LAW-OFFICES SHELLER, LUDWIG & BADEY bL ~'-'"' " ,< - 1.-: I , 'r'__.,,,,_,, - ~'~i specifically denied that plaintiffs claims are barred in any respect by the doctrine of assumption of risk. To the contrary, plaintiff was not negligent. 35. Denied. The allegations contained in paragraph 35 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. By way of further response, however, it is specifically denied that plaintiffs claims are barred in any respect by the doctrine of assumption of risk. To the contrary, plaintiff was not negligent. 36. Denied. The allegations contained in paragraph 36 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. To the extent that said allegations may be considered factual in nature, which assertion is specifically denied, after reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of said allegations; wherefore, the same are likewise denied and strict proof thereof is demanded at the time of trial. 37. Denied. The allegations contained in paragraph 37 of Answering Defendants' New Matter are deemed conclusions of law to which no further responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure; wherefore, the same are denied and strict proof thereof is demanded at the time of trial. To the extent that said allegations may be considered factual in nature, which assertion is specifically denied, after reasonable investigation, Plaintiff is without knowledge or information sufficient to form a belief as to the truth of said allegations; wherefore, the same are likewise denied and strict proof thereof is demanded at the LAW OFFICES SHELLER, LUDWIG & BADEY li_ 'l~ -,- '"' I time of trial. WHEREFORE, plaintiff demands judgment in her favor and against Answering Defendants. SHELLER, LUDWIG & BADEY B~2~ J 1. SHELLER, ESQUIRE Attorney for Plaintiff LAW OFFICES SHELLER, LUDWIG & BADEY _ '~ _~, .--: ," 0/ ~ lt~.:.,; -, ,.I I ',I" - ',.' "--~ VERIFICATION Jamie L. Sheller, Esquire, verifies that she is an attorney for the Plaintiff(s) in the foregoing action and that the facts set forth in the foregoing pleading are true and correct to the best of her knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Dated: I;) l~hO L. SHELLER LAW OFFICES SHELLER, LUOWIG & BAOEY Ii -;", ~ 'N 'IrL -1- t ~ " 'I. ~ "-," ~ '~i SHRI J .F.R, LUDWIG & BADEY By: Jamie L. Sheller, Esquire Identification No. 55722 1528 Walnut Street - Third Floor Philadelphia, PA 19102 215-790-7300 Attorney for Plaintiff CHRISTINE PARR COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. KEYSTONE SPINE CENTER, INC. and RUSSELLF. POOLE, P.T. CIVIL TERM NO. 00-6887 CERTIFICATE OF SERVICE I, Jamie L. Sheller, Esquire, attorney for Plaintiff, Christine Parr, hereby certify that I served a true and correct copy of the Reply of Plaintiff, Christine Parr, to New Matter of Defendants, Keystone Spine Center, Inc. and Russell F. Poole, P.T. by regular United States Mail on the following: Kenneth S. Fair, Esquire John C. Farrell, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 1845 Walnut Street Philadelphia, PA 19103 D," I)-I \5\ bG SHELLER, LKADEY Bg~ ~ JAMIE L. SHELLER, QUIRE Attorney for Plaintiff LAW OFFICES SHELLER, LUDWIG & BADEY i...." "~-;-"'lrml1~l""ilJiliJ'i~ " _. - ,:_;'- 11'1" ,-,~.- ,~---.'<<'< 'Jv<~).'''_"'",~, iH- ;.,~.~t~~iI~I.m.i1a!:i'..;"i'---' ~ ~, . . "Cd. . , ~ , - , -lliiIl5iUD < "'jf'"O'"" ,"""',,' ..E.;;:.-,!,: 11 B )1 I ! ! I I () c.,,) c; ~. (".:::J --,-~ ,- s: L,",) " ~ fT' ........ " '-I IT! rii <, 1"1--. LC ~~--, Z f::C.: C} (fJ ..,..", co , .< .,-". ~~~[) r;:: C:'J *\7 ~f;~ ~(,-:: -';" ===c.. Ct? Pc ~ Z ,...., ",> ~I <J1 ~ -<. . J ,,I '''foe 1_ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA pURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 ~:: ~ehTCr ^ c~~~~ I:~UIRE Attorney for DEFENDANT DEll-228878 47659 -LO]' " ~......;~ - _Ji '"'" ^' ~ "~~~.<, ''''-'' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- ,CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET At RO'l'ICB OF IR'.rBft TO ,SBRVE A SUBPOBNA TO PRODUCE DOCUMBR'l'S AND THINGS FOR DISCOV~KY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SRRT.T.1lR. ESQUIllE HCS on behalf of KElIIlETII S. PArI.. ESQUIRE inteuds to serve a subpoena identical to the one that is attached to this notice. Yon have twenty (20) days frCllll the date listed belOlf in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is _ived or if no objection is _de. then the subpoena _y.' be served. Complete copies of any reproduced records _y be ordered at your ezpense by cGllpleting the attached counsel card and returning same to HCS or by contacting our local MCS office. DlTE: 12/19/2000 MCS on behalf of &I5IOlE'fB S. PArI.. ESQUIRE Attomey for DEPEIIDAII'l' cc: KElIIlETII S. PArI.. ESQUIIB LA1lIlY NO'fBVBIIIl - 03125-00368 - 1M044705-SV Any questions regarding this _tter. contact TBB HCS GROUPDTC. 1601 MARD'f SfllEET '800 PIIILADBLPBIA. PA 19103 (215) 246-0900 DE02-140466 47659-C02 I.. >>> LOCA'!IOB L"IS'! <<< , ~ RECORDS REQUES'l'ED MEDICAL, Bu.LDIG, AIm X-IIAY(S) MEDICAL, Bu.LDIG, AIm X-IIAY(S) MEDICAL, Bu.LDIG, AIm X-BAYeS) MEDICAL AIm HOSPITAL Bu.L X-IIAY OBLY MEDICAL, Bu.LIRG, AIm X-IIAY(S) MEDICAL, Bu.LDIG, AIm X-IIAY(S) MEDICAL, Bu.LDIG, AIm X-IIAY(S) MEDICAL AIm HOSPITAL Bu.L X-IIAY OBLY EHPLOYHEII'I.' IRS1JIIARCB MEDICAL, BILLDIG, AIm X-KAyeS) MEDICAL, BILLIRG, AIm X-KAyeS) MEDICAL, Bu.LDIG, AIm X-KAyeS) O'!IIER O'!IIER .1 ~, .... '''''"'','~'." PAGIl : 1 LOCATJ:OR IfAMB ORTHOPEDIC IRSTJ:TlJD OF PEII1I& GOOD HOPE FAHILY PIIAC'fICB Cft.. MAGRE'!IC IMAGDIG "_YaK BAB.USBURG HOSPITAL BAB.USBURG HOSPITAL JOB S. RYCBAI. MD IWlTlWr RBBABILI'l'A'fIOR ASSOC; PBYSICURS OF IlBIIAB MEDICIRB KILTOR S. BDSBEY MEDICAL Cft. MILTOR S. IlEB.SBBY MEDICAL Cft. VIlIIt 104 CIGBA CORIIEC'Uctrf LIPE "IRS. S'lEVElf B. HORGA1fST.J:"IR.D.O. LBO D. FARRlU.T, MD JO"Yl1D SP01l'!S MBDICIRB IUD Am PBAIlHACY WEISS HAllDTS DB02-140466 47659- CO 2 - -'~ L 1- ~ '~ , - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:ORTHOPEDIC INSTITUTE OF PENNSYLVANIA (Name of Penon or Entity) Within twenty (20) days after servi<e of this subpoena. you are ordered by the <ourt to produ<e the following doc:uments ,or things: SEE ATTACHED ' u MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Address) You may deliver or mail legible <opies of the doc:uments or produ<e things requested by this subpoena. together with th., <erti/i<ate of <omplian<e,to the party making this request at the address listed above. You have the right to seek, in advan<e,the reasonable <ost of preparing the <opies or produdng the things sought. If you fail to produ<e the doc:uments or things required by this subpoena. within twenty (20) days after its servite, the paJrty serving this subpoena may seek a <ourt order <ompeJling you to <omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHlLA.,PA 19103 TELEPHONE: 21 S-246-0900 SUPREME COURT ID-Il AlTORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: J 2-J.5-00 Seal of the Court (Elf 7.Q7) . :" ,-- '"0 ",;1 ""' "" " '-\~"": 1_ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PENNA 875 POPLAR CHRUCH ROAD CAMP HILL, PA 17011 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and induding the present. Subject: CHRISTINE PARR , Social Security #: 175.48-3034 Date of Blrlh: 11-20-1957 SUIO-282016 47659 - L 0 '~ .- - L_ I . l ~,",J - ,~ 1-.."", J~ CERTIPICA'rE PREREQUISI'rE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 KCS on behalf of KENNETH S. FAIR, 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. KCS on behalf of DATE: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228879 47659 - L 0:2. ',,"~ - J i _~ ~--;~~~~,. (Iiil. ~ Mh , '~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE 01" Iltt&ft TO SERVE A SUBPOENA TO PRODUCE DOCtlIIBIl'1'S AND THINGS POR DISCOVERY PURSUAft TO RULE 4009.21 [ Rote: see enclosed list of locations ] TO: JAMIE L. SBBLLBII., ESQUIlIB HeS on behalf of 1BRIIB'l'JI S. FAIR, ESQUIllB intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frcu the date listed bel_ in which to file of record and serve upon the undersigned lU1 objection to the subpoena. If the twenty day notice period is _ived or if DO objection is made, then the subpoena _y,' be served. COIIIPlete copies of any reproduced records _y be ordered at your ezpense by cOlllPleting the attached counsel card and retumings_ to HeS or by contacting our local HeS office. DArB: 12/19/2000 HeS on behalf of KDlIBTII S. FAIR, ESQUIRE Attorney for DBFEIIDART , CC: KDlIBTII S. FAIR, ESQUl1IB LAIUlY HOTIIWBIIR - 03125-00368 - BM044705-SV Any questions regarding this matter, contact 'ftIE MCS GIOOP DfC. 1601 MAIID'l STREET #800 PiIILADBLPBIA, PA 19103 (215) 246-0900 DE02-140466 47659-C02 ~-I~ . ,- --~, - - >>> LOCATIOR LIST <<< , "" RECORDS REQUBSDD L" '. "lllllil ~~_'"'*"'!"-, PAGB: 1 LOCATIOR IWIB MEDICAL, BILLlJIG, AlID X-KAyeS) MEDICAL, BILLlJIG, AlID X-KAyeS) MEDICAL, BILLlJIG, AlIDX-KAyeS) MEDICAL AlID HOSPIfAL BILL X-KAY OBLY MEDICAL, BILLlJIG, AlID X-KAyes) MEDICAL, BILLlJIG, AlID X-lU.Y(S) MEDICAL, BILLDrG, AlID X..KAyeS) MEDICAL AlID HOSPITAL BILL X-KAY OBLY JilMPL01MBRT IRSUlWfCB MEDICAL, BILLIRG, AlID X-KAY(S) MEDICAL, BILLDrG, AlID X-KAY(S) MEDICAL, BILLIRG, AlID X-KAyeS) 0'1'BBll 0'1'BBll ORrBOPBDIC IRSTI'l'OU OP PBII1IA GOOD HOPE PAMILY PBACTICB Cft. MAGRBTIC DlAGDrG CBII'l'BB. IlAlB.ISBUl.G HOSPIrAL IlAlB.ISBURG HOSPITAL JOD S. RYCIfAJ:, MD 1Wl'llWl UllABILITATIOR ASSOC; PHYSICIANS OP UIIAB MEDICDII: MlL'fOR S. lIK1I~tlBY MEDICAL Cft" MlLroR S. IIEIlSBBY MEDICAL Cft.. WlRB. 104 CIGNA C01ll!lBcnCU'l LIFE IRS. STEVER B. MORGARSTBIR,D.O. LBO D. pARRRT T., MD .JOYREll. SPORTS MEDICIRB RID AID PIWIMACY WEISS KUllETS D802-140466 47659-C02 ~ ~~ " _ 1 " ~~ !:Jk""","_: , . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: GOOD HOPE FAMILY PHYSICIANS (Name of Penon or Entity) Within twenty (20) days after service of this sub"""na, you are ordered by the <ourlto produ<e the foJlowing do<uments or thing.: "SEE A"TTACHED , at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Mdren) You may deliver or mail legible <opies of the do<uments or produ<e thing. requested by this subpoena, together with th" <ertifi<ate of <omplian<e, to the, party making this request at the address listed above. You have the right to seek. in advan<e, the reasonable <ost of preparing the <opies or produdng the thing. sought. If you fail to produ<e the do<uments or things required by this subpoena, within twenty (20) days after its servi<e, the party serving this subpoena may seek a <our! order rompelling you to <omply with It. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR, ESQUIRE 1$45 WALNUT ST., 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT 11)1: ATI'ORNEY FOR: DEFENDANT NAME: ADDRESS: DATE: J 2,-/5-00, Seal of the Court (Eff 7/97) j, , . ,~ ~-"~~>:><h~ . ~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GOOD HOPE FAMILY PRACTICE CTR. 1830 GOOD HOPE ROAD ENOLA, PA 17025 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: ,up to and including the present. Subject: CHRISTINE PARR . Social Security #: 175-48.3034 Date of Birth: 11-20-1957 SUIO-Z8Z018 47659 - L 0 :2 --1<"- ,I lLIlIiI'~!iilff"; '- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228880 4765 9 -LO 3 ~..... ., ,1, I ~ ,!!!, . - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICB OF IlI1'.rBlI1'.r '1'0 SBRVE A SUBPOBRA '1'0 PRODUCB DOCUIIBJ.ft'S AND THINGS FOR DISCOVERY PURSUAN'r '1'0 RULE 4009.21 [ Note: see enclosed list of locations ] TO: .JAMIE L. SHIU.T.n, ESQUIBE HCS on behalf of DII!lIETIl S. FAn, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fr(llll. the date listed below i.I1 which to file of record and serve upon the UI1dersiped an objection to the subpoena. If the twenty day notice period is _ived or if no objection is made, then the subpoena maJ' be served. Complete copies of any reproduced records may be ordered at your expense by clllllpleti.l1g the attached counsel card and returning same to MCS or by contacting our local HCS office. DArE: 12/19/2000 HCS on behalf of JWuuU S. FAn, ESQUIRE Attorney for DIttERDAIrr cc: DlOlBTIl S. FAn, BSQUIU LAlUlY RO'fIIVBD - 03125-00368 - HMO""70S-SV Any questions regarding this matter, contact TIlB HCS GIlOUP INC. 1601 MAIK1n' STREET #800 PIlILAIlBLPBIA. PA 19103 (215) 246-0900 DE02-l40466 47659-C02 :;-= " ~ >>> LOCATIOR LIST <<< , ' IlBCOllDS REQUESTED ~..~~ ~ T-Ulli'--'''''''''~!d,''',;_'- PAGE, 1 LOCATIOR RAME M1mICAL, BILLIRG, ARD X-RAY(S) M1mICAL, BILLIRG, ARD X-RAY(S) M1mICAL, BILLIRG, ARD X-RAY(S) M1mICAL AND HOSPITAL BILL X-RAY ONLY M1mICAL, BILLIlf!;, ARD X-RAY(S) M1mICAL, BILLIRG, ARD X-RAY(S) MEDICAL, BILLIRG, ARD X-RAY(S) M1mICAL ARD HOSPITAL BILL X-RAY ONLY EMPLOYMER'1' IRSOBARCB M1mICAL, BILLIRG, ARD X-RAY(S) M1mICAL. BILLDlG. AIlD X..RAY(S) M1mICAL, BILLIRG, AIlD X-RAY(S) O'fBD. O'fBD. ORTHOPEDIC IRS'fI'lU'l'B OF PEIIlU. GOOD HOPI FAMILY PRACTICE cn. HAGD'fIC IHAGIRG (;JSIlIYAIl HAIUlISBUllG HOSPITAL JlAlRISBUllG HOSPITAL .JOD S. RYCHAlt. MD 1Wl'l'lWl RBHABILI'l'ATIOR ASSOC; PHYSICIAlfS OF ~ M1mICIIIB HILTOII S. BBllSIIEY MImlCAL cn.. HILTON S. BBllSIIEY M1mICAL cn.. WIn 10,4 CIGlfA COIfllBC'fIClJ'l' LIFE DlS. ST.EVBIf E. MOIlGAlfSTEIR,D.O. LBO D. F~llllRT.T., MD .JOYJID SPORTS M1mICDIE lUTE AID PIWlMACY VBISS IWlDTS DE02-140466 47659 - C 0 Z -.. I -'-' . ~~- ."-~ - ~,~""%~. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00"06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FORlllAGNETIC IMAGING CENTER (Name of Penon or Enllly) Within twenty (20) days after service of this subpoena. you are ordered by the <ourt to produ<e the following do<:uments or things: SEE ATTACHED ' " n MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,FA 19103 (Address} You may deliver or mail legible <opies of the dO(uments or produ<e things requested by this subpoena, together with th.' <ertifi<ate of <omplian<e, to the party making this request at the address listed above. You have the right to seek, in advan<e, the reasonable <ost of preparing the <opies or produdng the things sought. If you fail to produ<e the dO(Uments or things required by this subpoena, within twenty (20) days after its servi<e, the paJrty serving this subpoena may seek a <ourt order <ompelling you to <omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHlLA. ,FA 19103 TELEPHONE: 215-246-0900 SUPREME COURT aD" ATTORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: I1-15.()Q Seal of the Court (Eff.7/Q7j ~~~, -.. -- I, - JlIJ;ui ~,- ~ n '-~,:: , - EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17055 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, corres{londence, files and memorandums, handwritten notes, original X-Rays, bilhng and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 5U10-282020 47659 - L 0 3 1",_." ~ 1- , _.< CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS P ARIt TERM, -VS. CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL .. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-22888l 47659 - L 0 '+ ~,,-,--, ~'iJ-.<, COMt-1:0NWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF IR'.rBlft TO SERVE A SUBPOENA TO PRODUCE DOC1JMBRTS AND THINGS FOR DIScoVBRY PURSUANT TO RULE 4009.21 [ Hote. see enclosed list of locations ] TO: JAHIB L. SBBLLBR, ESQ1JDIB MeS on behalf of DDE'fII S. FAIR, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frma the date listed below in which to file of record'sod serve upon the UDdersigned 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. COlIIplete copies of any reproduced records may be ordered at your expense by cOlllpleting the attached counsel card and returning s_ to MeS or by contacting our local MeS office. DArE. 12/19/2000 MeS on behalf of DlUIE'fII S. PAIR. ESQUIRE Attorney for DEPERDA1fr cc: DlUIE'fII S. PAIR. ESQ1JIU LAIIlI.Y \!IO'fIIVEJD. - 03125-00368 - BK044705-SV Any questions regarding this matter, contact THE MeS GROUP DC. 1601 IWlD'l STREET '800 PJIILADELPIIU. PA 19103 (215) 246-0900 DE02-140466 47659-C02 "" I...~ " I >>> LOCA'U:OB LIST <<< ~ I , IiIiilli' ~ ~~~ - ~ - """'. PAGE. 1 1lECORDS REQUESTED LOCA'lIOB HAMB M1mICAL. BILLDfG. AJID X-RAY(S) M1mICAL. BILLI1IG. AJID X-RAY(S) M1mICAL. BILLDfG. AJID X-RAY(S) M1mICAL Alm HOSPITAL BILL X-RAY OBLY M1mICAL. BILLDfG. AJID X-RAY(S) M1mICAL. BILLDfG. AJID X-RAY(S) M1mICAL. BILLDfG. AJID X-RAY(S) M1mICAL AJID HOSPITAL BILL X-RAY OBLY EMPLOYMD'l' INSURAllCE M1mICAL. BILLDfG. AJID X-RAY(S) M1mICAL. BILLDfG. AJID X-RAY(S) M1mICAL. BILLIRG. AJID X-RAY(S) OTBEll. OTBEll. OR'lBOPBDIC DfS'fiTUTB OF PEIIBA OOODHOPE FAHlLY PIAC'lICE Cft. MAGBE'fiC IHAGI1IG CEIITBR BARRISBURG HOSPITAL BARRISBORG HOSPITAL JOB S. RYCBAJ:. MD IWlTIWI REHABILITATIOB ASSOC; PHYSICIANS OF IlBILU HEDICDlB MILTON S. HERSHEY M1mICAL CTR.. MILTOB S. HERSHEY M1mICAL CTR. WIIIJ: 104 CIGRA CONIIEC'fiCU'l LIFE IRS. STEVElI E. MOIlGAlISTEIB.D.O. LEO D. F.ARRRJ.T., MD JOYBD. SPORTS M1mICIHI!: RIm AID PBAIlMACY WEISS IfAllUTS DE02-140466 476S9-C02 " - ""~~.-;r,",", COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL (Name of Penon or Entity) Within twenty (20) days after service of this subpoena,J'ou are ordered by the court to produce the following documents or things: SEE ATTACHED ' ' at MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103' (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with th" 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 "rder compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT IDlJ; ATTORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: J 2- 1-5 -(){j ~i60UR ~ IY1 0/ .()'1'1 f Jl .JYYl Depu Seal of the Court (Eff. 7/97) ~ - ~ ~ ~I I, " '~~- EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT STREET HARRISBURG, PA 171012099 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten' notes, billing and payment records, relating to any examination, consultation, care or treatment of patient. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUIO-282022 4765 9 - L 0 '. -- I~- ~:., " ~ ;;11;,;-., CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 KCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228882 47659 -LO 5 ,~' "~ ',~ . ~- -~-L -"'>III,"",':!I;Ii;~' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -V$- CASE NO: 00-06887 KEYSTONE SPINE CENTEa. INC., ET AL NOTICB OP IN'l'BN'l' TO SBRVE A SUBPQBNA TO PRODUCB DOCuJ!I5ftS AND THINGS FOR DISCOVBRY PUR$1JAIl'.r TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. smn.T.RR. ESQUIllB HeS on behalf of KEIIP!B S. PAIIl. ESQUIRE intends to serve a subpoena iclenticalto the one that is attached to this notice. You have twenty (20) days frma 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 _ived or if no objection is made. then the subpoena may" be served. COIIIplete copies of any reproduced records may be ordered at your ezpeDse by cOlllpleting the attached counsel card and returning same to HeS or by contacting our local HeS office. DATE: 12/19/2000 HeS on behalf of lUuuuua S. PAIIl. ESQUlIlE Attorney for imPElmAIlT CC: ullIIEtII S. PAIIl. BSQUIllB LAlIllY 1IO!IlWBIIIl - 03125-00368 - BH044705-SV Any questions regarding this matter. contact TIlE HeS GROUP UC. 1601 HARDt STIlEET #800 PIIILADELPBIA. PA 19103 (215) 246-0900 DE02-140466 47659-COZ ~ m >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLIKG, AIID X-RAY(S) MEDICAL, BILLDG, AIID X-RAY(S) MEDICAL, BILLIKG, AIID X-RAY(S) MEDICAL AIID HOSPI'fAL BILL X-RAY ONLY MEDICAL, BILLDG, AIID X-RAY(S) MEDICAL, BILLDG, AIID X-RAY(S) MEDICAL, BILLDG, AIID X-RAY(S) MEDICAL AIID HOSPITAL BILL X-RAY ONLY EMPLOYImIT DSUIWICE MEDICAL, BILLIKG, AIID X-RAY(S) MEDICAL, BILLDG, AIID X-RAY(S) MEDICAL, BILLIlIG, AlID X-RAY(S) OTllBll OTllBll ,I '" " lIlI ~ "'""', -"_,""~. PAGE: 1 LOCATION JIAME ORTHOPEDIC DSTITll'lE OF PEII1IA GOOD HOPE FAKILY PRACTICE C'l'R. MAGllBTIC DfAGIKG CEIITU BAIlIlISBUIlG HOSPI'fAL BAIlIlISBUIlG HOSPI'fAL .JOD S. RYCBAI:, MD BAJI.'1'IWI IlEBABILITATIOIJ ASSOC; PBYSICIAlfS OF BBBAa MEDICIllE HlLTOIJ S. BEIlSIIlY MEDICAL cn. HlLTOIJ S. BEIlSIIlY MEDICAL cn. WI1Q[ 104 CIGBA COBIIECTICUT LID D5. S'RVElI E. MORGAIISTEIIJ, D.O. LEO D. FAlIRIlI.T., MD .JOYllEJl. SPORTS MEDICIllE IlITE AID PBAllKACY llEISS MAIlUTS DE02-140466 47659-C02 ~ ,- ~"'-r."" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HARRISBURG (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the folIowing documents 'Dr things: SEE A'J:TACHED ' at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with th., certifkate 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 paJrty 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: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHILA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT II) f: ATIORNEY FOR: NAME: AODRESS: DEFENDANT DATE: J A -Is -00 Seal of the Court (Eff i,' 97) - EXPlANATION OF REQUI TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT STREET HARRISBURG, PA 171012099 RE: 47659 CHRISTINE PARR Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , . Social Security #: 175.48-3034 Date or Birth: 11-20-1957 ,-- !l(-!N' D RECORDS . SUIO-282024 47659 -LO 5 "I~ I ,-.-,- -,~~.I.~ '''''0_ CERTIFICATE PREREQUISITETETETETETETETETETE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 KCS on behalf of KENNETH S. FAIR, 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. KCS on behalf of DATE: 0110812001 KENNETH S. FAIR, ESQUIRE Attorney fot DEFENDANT DEll-228883 47659 -LO 6 '!l\-~' ~- c "" ~ . ~"_ .c_", COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COMMON PLEAS PARR TERM, -vs- CASE NO: 00-06887 KEYSTONE SPINE CENTER., INC.. ET AL NOTICE 01" In..rJSn't TO SERVE A SUBPQENA TO PRODUCE OOl.:u_.rS AND TBIRGS FOR DISCOVERY PURSlJA1iT TO" RULE 4009.21 [ Note: see enclosed list of locations ] TO: .JAMIB L. SART.T.RR. ESQUIllB MCS on behalf of DII1IETII S. FAIR, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fr_ the date Hsted bel_ in which to, file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is _ived or if no objection is made, then the subpoena may.. be servecl.COIIIplete copies of any reproduced records may be ordered at your ezpeIlse by cOlllpleting the attached counsel card and returning S8Dle to MCS or by contacting our local MCS office. DArB: 12/19/2000 MCS on behalf of DllMBTB S. FAn, ESQUIRE Attorney for uul5lWAR'1' CC: DlOO!:TII S. FAn, ESQUDI LARIlY IIO'fBVBIIIl - 03125-00368 - BM044705-SV Any questions regardJ.n& this matter, contact TIlE MCS GIlOUP IIIC. 1601 1WlKB! S'lREE! #800 PllILADELPBIA, PA 19103 (215) 246-0900 DE02-140466 47659 -co 2 = -, >>> LOCATIO. LIST <<< RECORDS REQUES'lBJ) MEDICAL. BILLIlIG. AIID X-RAY(S) MEDICAL. BILLIlIG, AIID X-RAY(S) MEDICAL, BILLIIfG, AIID X-RAY(S) MEDICAL AIm HOSPITAL BILL X-RAY ONLY MEDICAL. BILLllfG. AIID X-RAY(S) MEDICAL. BILLllfG. AIID X-RAY(S) MEDICAL. BILLllfG, AIID X-RAY(S) MEDICAL AIID HOSPITAL BILL X-RAY ONLY EMPLOYMEIl'f llfSUlWrCE MEDICAL. BILLIlIG. AIID X-RAY(S) MEDICAL. BILLllfG. AlII) X-RAY(S) MEDICAL. BILLllfG. AIID X-RAY(S) OTllEll OTllEll , ' '~! PAGE. 1 LOCATIO. lWtE ORTHOPEDIC IJISTITU'lE OF PEII1IA GOOD HOPE FAMILY PRACTICE cn. MAGNETIC IHAGIJIG CBNTBR. BA1IllISBIIRG HOSPITAL BAIUlISBIIRG HOSPITAL .lOD S. IlYCIIAK, HD BAIlTIWI REBABILITATIO. ASSOC; PBYSICUIlS OF REBAB MEDICDlK MILro. S. IlERSBBY MEDICAL cn" MILro. S. IlERSBBY MEDICAL cn., WIn 104 CIGIIA COlOlECTICOT LIFE IJIS. STEVEII B. KOB.GAlIS'lBllf.D.O. LBO D. FA.lI!lI!\tU.. HD .lOYRBll SPOB.TS MEDICDlK RID AID PIlAllMACY WEISS lWtDTS DB02-140466 47659-C02 - L', ~, iiiE::( COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERYPURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:JOHN S. RYCHAK, M.D. (Name of Person or Entity) Within twenty (20) days after servi.e of this subpoena, yC!u are ordered by the .our! to produ.e the following do<ument., or things: SEE ATTACHED ' u MGS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You may deliver or mail legible .opies of the do<uments or produ.e things requested by this subpoena, together with the .ertifi.ate of .omplian.e, to the party making this request at the address listed above. You have the right to seek, in advan.e, the reasonable .os! of preparing the .opies or produdng the things sought. If you fail to produ.e the do<uments or things required by this subpoena, within twenty (20) clays after its servioe, the Pilrty serving this subpoena may seek a 'Our! order .ompelling you to .omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHILA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT lOt: ATTORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: J 1- J.5-()() Seal of the Court (Eff :';Q7) ,_' ~ < ~ ....1 I. .~~~,,~""", EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN S. RYCHAK, MD 2800 GREEN STREET HARRISBURG ORTHO. HARRISBURG, PA 17110 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, ,consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SU10-282026 47 6S9-LO is - ~-, ,-I. .......~:-! CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUAIIT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228884 4 76S9-LO 7 ."vll . ~I_-.- ~ j ~. ",'p- "~-'~~_"' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER of: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF IN'rER'r TO SERVE A SUBPOENA TO PROPUCE DOCUJI1ISlftS 'JUm THINGS FOR DISCOVERY PURSUAN'r TO RULE 4009.21 [ Hote: see enclosed list of locations ] TO: JAHIB L. SII1U.T.n, ESQUIRE HCS on belullf of UIIlIEYB S. FAlB., ESQUIQ intends to serve a subpoena identical to the one that is attached to 'this notice. You have t1IeIlty (20) days freD the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the t1IeIlty day notice period is _!ved or if no objection is _de, then the subpoena _y' be served. Complete copies of 8DY reproduced records _y be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local HCS office. DATE: 1211912000 MCS on behalf of JUUIlImtd S. FAlB., ESQUIRE Attorney for DEFEHDAHT , CC: DHIlB'rIl S. FAlB., ESQUIU LAIUlY lfOTIIWBIIR. - 03125-00368 - 1IK044705-SV Any questions regarding this _tter, contact THE MCS GROUP DC. 1601 IWlD'f S'lIIEET #800 PIIILADBLPIIIA, PA 19103 (215) 246-0900 DE02-l40466 47659 - C 01 2. " " >>> LOCATIO. LIST <<< BooRDS RBQUES'fED MEDICAL. BILLIlIG. ARD X-KAyeS) MEDICAL. BILLIlIG, ARD X-KAyeS) MEDICAL. BILLDlG. ARD X-KAYeS) MEDICAL ARD HOSPITAL BILL X-KAY OBLY MEDICAL. BILLIlIG. ARD X-KAyes) MEDICAL. BILLDlG. ARD X-BAyeS) MEDICAL. BILLIlIG. ARD X-BAyeS) MEDICAL ARD HOSPITAL BILL X-BAY OBLY EMPLOYMD'l' IRStJRAIICE MEDICAL. BILLIIIG. ARD X-BAyeS) MEDICAL. BILLIRG. ARD X-KAyeS) MEDICAL. BILLIlIG. ARD X-BAyeS) OTIIBR OTIIBR w '~ '-", ~!<u IIIMIN..Y~, PAGE: 1 LOCATIO. DHB OB.1'BOPBDIC IRSTI'1'lJU OF PE1IRA GOOD HOR FAMILY PRACTICE Cft. MAGRE'rIC IMAGDlG CBitUJL IWUUSBUB.G HOSPITAL IWUUSBUB.G HOSPITAL .lOBI S. RYCIW[. MD BAll!IWJ REllABILITATIOIf ASSOC; PBYSICIAlIS OF ilEIwl MEDICIRB KILTOR S. BEIlSBBY MEDICAL eft.. KILTOII S. IIEIlSBBY MEDICAL Cft.. VIllI[ 104 CIGIIA oollllECUctl'f LIFJ! IRS. STEVEII E. MORGAlfS'fEIR.D.O. LEO D. F,AllllRU.. NO JOYllE\l. SPORTS MEDICIRB RITE AID PIIA1lHACY WEISS IfARDTS DE02-140466 47659-C02 I ~ ., I. - "~ '-- ' ~. ~ " ,I!-'- ~ ; COMMONWEALTH OF PENNSYLVANIA COUNTY OF ctJMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY RURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HARTMAN REHAB ASSOCIATES (Name of Pe...... or Entity) Within twenty (20) days after service of this subjl_oena,~you are ordered by the court to produce the following documents 'Of things: SEE ATTACHED . at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addreoo) 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 althe. 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: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT lDtt ATIORNEY FOR: DEFENDANT NAME: ADDRESS: DATE: 12.-IS-OO Seal of the Court (Eff. 7/97) .0> . ~. I -" -'~ iiiI: -'~1: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARTMAN REHABILITATION ASSOC. 2645 N. 3RD STREET SUITE 490 HARRISBURG, PA 17110 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, bilhng and payment records, relating to any examination, .consultation, care or treatment. Dates Reque$ted: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUIO-282028 47 659-LO 7 "i;Uj I . '.' ." ~-'iiw-,' CERTIFICATE PREREQUISITE TO SERVllCE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF' COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S., FAIR, ESQUIRE Attorney for DEFENDANT DEll-228885 47659-L08 , ~ I " -.I" " l .," ,; " ~~ COMM:ONWEALTH OF PENNS~VANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF IIrl'Elft' TO SERVE A SUBPOENA TO PRODUCE DOCUHBNTS AND THINGS FOR DISCOVERY PURSUAH'l' TO RULE 4009.21 [ Bote: see enclosed list of locations ] TO: .JAMIE L. SIIRI.T.RII. ESQUIIB MCS OIl behalf of DIlIIE'IB S. PAIl.. ESQUlllE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOD 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 _ived or if no objectiOll is _de. then the subpoena may. be served. COIIIplete copies of any reproduced records _y be ordered at your ezpense by cOlllpleting the attached counsel card and returning S8llle to MCS or by contacting our local MCS office. DATE: 12/19/2000 MCS OIl behalf of UlllU5fll S. PAIB.. ESQUlIB Attorlll!)' for .li.lu<lUIuAlft CC: DIlIIETR S. PAIB.. BSQUIU LADY IlOTRWIIII. - 03125-00368 - BM044705-SV Any questions regarding this matter. contact TIll MCS GROUP IlIC. 1601 MAIIKft STREET #800 PIIILADELPBIA. PA 19103 (215) 246-0900 DE02-140466 47659-C02 ,,~ J - >>> LOCATION LIST <<< RECORDS REQUESTBD I ~' " ~ ' n-~' 1m,"' PAGE, 1 LOCATION IIAHE MBDICAL, BILLIIIG, AIJD X-KAyeS) MBDICAL, BILLIIIG, AIJD x-byes) MBDICAL, BILLIIIG, AIJD X-RAY(S) MBDICAL AIJD HOSPITAL BILL X-KAY OBLY MBDICAL, BILLIlfG, AIJD X-KAYeS) MBDICAL, BILLIIIG, AIJD X-KAyes) MBDICAL, BILLING, AIJD X-KAYeS) MBDICAL AIJD HOSPITAL BILL X-KAY OBLY EMPLOYMEIIT IlfStlBARCE MBDICAL, BILLIIIG, AIJD X-KAY(S) MBDICAL, BILLIlfG, AIJD X-KAyeS) MBDICAL, BILLIIIG, AIJD X-KAyeS) 0'lBKIl O'lBBll ORTIIOPEDlC IlfS1'I'lUTE OF PDIIA GOOD BOPE FAMILY P1lACTICE CrR.. HAGDTIC IMAGIIIG ~1[_ IWIllISBURG HOSPITAL IWIllISBURG HOSPITAL .JOD S. RYCBAJ;, MD 1IAIl'l'lWl IIBIWIILITATION ASSOC. PBYSICIAIfS OF ~ MBDICIJIE MILTON S. IIEIlSBEY MBDICAL CrR. MILtON S. IIEIlSBEY MBDlCAL CrR. WDIJ: 104 CIG!IIA COlOlECTICUT LIFE IlfS. S'fE'lElI E. KORGARSTEIII,D.O. LEO D. FARRRI.T., MD .JOYREll SPORTS MBDICIJIE RIrR AID PlWlMACY WEISS MAllDTS DE02-140466 47659-C02 . ,~ ~""'I""'~"~"" COMMONWEALTH OF PENNSYLVANIA COUNTY OF cUMBERLAND PARR VS File No. 00-06887 KEystONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PuRSUANt TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:PHYSICIANS OF REHAB. MEDICINE, PC (Name of Penon or Enlity) Within twenty (20) days after service of this sub~na, you, are ordered by the court to produce the following documents or things: SEE ATTACHED , at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addresl) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with th.. 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) clays 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: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST., 19TH FLOOR PHILA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT 11)" ATTORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: J 'J..-Jj-() 0 Seal of the Court (Eff, 7/97) ,I' I, .~ - '~~~-",-; EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PHYSICIANS OF REHAB MEDICINE 450 POWERS AVE HARRISBURG, P A 17009 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requestecl: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUIO-282030 4765 9 -LOB """"~ 1'- ~ " -I, ,J, ~~"_.~~~- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228886 47 6S9-LO 9 ~, ,1- 'IU'" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., &T AL NOTICE OF IJrrISNr TO SBRVE A SUBPOENA TO PRODUCE DOCUJlBH'rS AND THINGS FOR DISCOVERY POR$UART TO RULE 4009.21 [ Bote: see enclosed list of locations ] TO: .JAMIK L. SRRT.T.R1I, ESQUDlK MCS on behalf of Al5llllUiTIl S. PAn, ESQUIQ intends to serve a subpoena identical to the one that is attached to '.this notice. You have wenty (20) clays f~ the clate listed below in which to file of record and serve upon the undersiped an objection to the subpoena. If the wenty clay notice period is _ived or if no objection is made, then the subpoena maJ:' be served. CoIIIplete copies of any reproduced records may be lirderedat your ezpeIlse by cOIIIpleting the attached counsel card and returning SlUE to MCS or by contactfnaour local MCS office. DArE: 12119/2000 MCS OIl behalf of UllllllftI S. FAn, ESQUIIlE Attorney for DEPElmAIl'f CC: DllBJTII S. PAn, ESQUIBB LAIUlY RO'lIIWBBIl - 03125-00368 - BM04470S-SV Any questions regarding this matter, contact TIIB MCS GKOUP IBC. 1601 IfAIlEBT STREET #800 PIIILADELPIIIA. PA 19103 (215) 246-0900 DE02-l40466 4- 7659-C02 ,~" ~'"' >>> LOCATIOR LIST <<< RECOlIDS REQUESTED MBDICAL, BILLIRG, AIID X-KAyeS) MBDICAL, BILLIRG, AIID X-KAyeS) MBDICAL, BILLIRG, AIID X-KAyeS) MBDICAL AIID HOSPITAL BILL X-KAY OBLY MBDICAL, BILLIRG, AIID X-KAyes) MBDICAL, BILLIRG, AIID X-KAyeS) MBDICAL, BILLIlfG, AIID X-KAyeS) MBDICAL AIlIli HOSPITAL BILL X-KAY OBLY EMPLOYMEIIT IlfSURARCB MBDICAL, BILLIlfG, AIID X-KAyeS) MBDICAL. BILLIlfG. AIID X-KAyeS) MBDICAL, BILLIIlG, AIID X-KAyeS) 0'l'llBll. 0'l'llBll. ...1. &' 'c ~ ~-4"~'~J.~"", PAGE: :1 LOCATIOR RAMB ORTHOPEDIC IIISTI'rtI'lB OF PBRRA GOOD HOPE FAMILY PRACTICB Cft. MAGRETIC IMAGIRG CU:raK BAIlllISBURG HOSPI'l'AL HARRISBURG HOSPITAL JOIIR S. RYCIIAK, MD BARTJWI UBAIIILI'lATIOR ASsac; PHYSICIANS OF 1lEIIAB MBDICIBB MILTON S. IIB1lSI1BY MBDICAL Cft.. MILTOR S. IIB1lSI1BY MBDICAL Cft" VIJI1t 104 CIGBA COBBBCTICUT LIFE IllS. STBVBR B. MORGARSTEIR,D.O. LBO D. FARRRU.. MD JOYRBR SPORTS MBDICIBB RITE AID PIWIKACY WEISS MAJlDTS .' DB02-140466 476S9-C02 , j l~ ~'lW", COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:MILTON S. HERSHEY MEDICAL CENTER (Name of Person or ~tity) Within twenty (20) days after servioe of this subpoena, you are ordered by the oourt to produoe the following do<:uments ,or things: SEE ATTACHED . at MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Addren) You may deliver or mail legible oopies of the documents or produoe things requested by this subpoena, together with thE! oertifioate of oomplianoe, to the party making this request at the address listed above. You have the right to seek, in advanoe, the reasonable oost of preparing the oopies or produdng the things sought. If you fail to produoe the do<:uments or things required by this subpoena, within twenty (20) days after its servioe, the party serving this subpoena may seek a oourt order oompelling you to oomply with It. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR. ESQUIRE i845 WALNUT ST., 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT m t: ATIORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: I J..- /.5 -00 Seal of the Court (Eff 7/9'7) .~. ;, .I' - lJr<<,'. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL CTR. 500 UNIVERSITY DRIVE HERSHEY, P A 17033 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment of patient. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175.48.3034 Date of Birth: 11.20.1957 SUlO-282032 4765 9-L09 .~< ~- I" I, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or deliver",d 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 s.erved is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DATE: 01/08/2001 DEll-228887 47659-L10 ,.-[, _"1 ~"""-~-l1O,l<< COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICB OF In"J:JSJr.l' TO SBRVE A SUBPQBNA TO PRODUCB DOCUMENTS AND THINGS FOR DISCOVERY PUR~ TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: .JAMIE L. SiIRT.T.1fR. ESQUDlB MeS on behalf of KEIIIIE!II S. PAIlI.. ESQUIRE intends to sene a subpoena identical to the one that is attached to :t.his 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 _ived or if no objection is made. then the subpoena may.. besened. COIIIplete copies of any reproduced records may be ordered at your ezpense by cOlllpleting the attached counsel card and returning same to MeS or by contacting our local MeS office. DArE: 12/19/2000 MeS on behalf of lUU'I1my-' S. PAIlI.. ESQUIRE Attomey for DEPElOlAIIt' cc: KEIIIIE!II S. PAIlI.. ESQUIU LARIlY IIOrIlW_ - 03125-00368 - BM044105-SV Any questions regarding this matter. contact 'lIIE MeS GIlOUP IJIC. 1601 IWlDT STREET #800 PBILADBLPIlIA. PI. 19103 (215) 246-0900 DE02-140466 47659-C02 - ,I >>> LOCATIOB LIST <<< RECORDS REQUES'lED MEDICAL, BI.LLI.BG, AIID X-RAY(S) MEDICAL, BI.LLI.BG, AIID X-RAY(S) MEDICAL, BI.LLI.BG, AIID X-RAY(S) MEDICAL AIID SOSPI'l'AL BI.LL X-RAY ONLY MEDICAL, BI.LLI.BG, AIID X-RAY(S) MEDICAL, BI.LLIlfG, AIID X-RAY(S) MEDICAL, BI.LLI.BG, AIID X-RAY(S) MEDICAL AIID SOSPI'fAL BILL X-RAY ONLY EMPLOYMIDIT IlfSUIWICE MEDICAL, BI.LLI.BG, AIID X-RAY(S) MEDICAL, BI.LLIlfG, AIID X-RAY(S) MEDICAL, BI.LLIBG, AIID X-RAY(S) O'l'llBR O'l'llBR .. """"'-'" PAGB: JL LOCATIOR IWIE OR'fHOPBDIC IRSTI'fUTB OP PBIIRA GOOD SOPl PAMILY PRACTICE cn.. KAGllBTIC IHAGI.BG WiIIUIl BARJlISBUB.G BOSPI'l'AL BARJlISBUB.G BOSPI'fAL JOD S. RYCBAI:, MD BAll.TIWI llEBABILI'fATIOR ASSOC; PBYSICIAlfS OP llEBAB MEDIClRB HIL'fOR S. BBKSIIBYMEDICAL cn.. HIL'lOB S. IIERSIIBY MEDICAL cn. WlRX 104 CIGIIA COHRECTIClJ'l' LIPK DfS. S'fEVElI E. HORGARSTEIR,D.O. LEO D. FAJ>lIRU, MD JOYllBR. SPORTS MEDICIRE lUTE AID PIIAllMACY WEISS HARDTS DE02-140466 47659-C02 ~, 'l _~ ~-"" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: MUTON S. HERSHEY MEDICAL CENTER (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered 'by the tourt to produte the following dotuments or things: SEE ATTACHED . at MCS GROUP INC., 1601 MARKET ST., 1/800, PHILA. ,PA 19103 (Ad""'") You may deliver or mail legible topies of the dotuments or prod ute things requested by this subpoena, together with thl! tertlficate of tompIianc:e, to the party making this request at the address listed above. You have the right to seek, in advante, the reasonable tost of preparing the topies or produdng the things sought. If you fail to produte the documents or things required by this subpoena, within twenty (20) days after its servite, the party serving this subpoena may seek a tourt order tompelling you to tomply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR. ESQUIRE 18'45 WALNUT ST., 19TH FLOOR PHlLA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT mil ATfORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: /1-/.5-00 Seal of the Court (Eff.7/97) ",.~~ ,,,. "~ ~ ,=" ,__ J '''mitt EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL erR. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 47659 CHRISTINE PARR Any and all X-Rays pertaining to patient. Date5 Requested: up to and including the present. Subject: CHRISTINE PARR , . Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SU10-282034 47 6S9-L10 I "'= ~ ~ ~~.- 'lll.,; JM'i-~' CERTIFICATE PREREQUISITE TO. SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228888 47659 -Lll -,,~=~ I" ~ -lilljU!!l~_.. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF, COURT OF COMMON PLEAS PARR TERM. -VS- CASE NO. 00-06887 KEYSTONE SPINE CENTER. INC., ET At NOTICB OF IR'.rElI'l! TO SBRVE A SUBPOBNA '1'0 PRODUCB DOClJ:IIBftS AIm THINGS FOR DISCOVERY PURStJAlrI' TO RULE 4009.21 [ Note. see enclosed list of locations ] TO. .JAMIE L. SRRT.T.R1I, ESQUIRE IfCS on behalf of IU5l'IIIJ5TJI S. FAlB., ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fraa the date listed belcnr 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 _de, then the subpoena _yo' be served. CClIIIplete copies of any reproduced records _y be ordered at your ezpense by 'cCllllpleting the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/19/2000 MCS on behalf of IU5IIItftB S. FAlB., ESQUIRE Attomey for DEPEIIDAlft' cc: DIIIIE'lB S. FAlB., ISQUDB LAIlIlY IIO'lIIWEIDl - 03125-00368 - BK044705-SV Imy qul!stions regarding this _tter, contact 'l'II& MCS GBOUP nrc. 1601 MAUlT S'lRD'l '800 PIIILADILPBIA, PA 19103 (215) 246-0900 DI02-140466 476.59-C02 ,-'" >>> LOCATION LIST <<< RECORDS REQlIES'rKD MEDICAlo, BILLDIG, AIID X-RAyeS) MEDICAlo, BILLDIG. AIID X-RAyeS) MEDICAlo, BILLDIG, AIID X-RAyeS) MEDICAlo AIID HOSPITAL BILL X-RAY OBLY MEDICAlo, BILLDIG, AIID X-RAyeS) MEDICAlo, BILLDIG, AIID X-RAYeS) MEDICAl., BILLIlfG, AIID X-RAyeS) MEDICAl. AIID HOSPITAL BILL X-RAY OBLY 1lMPLOYMEB'f IIIS111lA1JCE MEDICAlo, BILLDIG. AIID X-RAyeS) MEDICAlo, BILLDIG, AIID X-RAyeS) MEDICAlo, BILLIIIG, AIID X-RAyeS) OTllBll OTllBll I ~ilIl~~.,- PAGE: l. LOCAUON RAMB OIl1'BOPBDIC IlfSU'lll'fB OP PIOOIA GOOD HOPE PAMILY PRACUCE Cft. MAGHEUC IHAGDIG CDTBIl IIAIlllISBUIlG HOSPITAL IIAIlllISBUIlG HOSPITAL .JOB S. 1lYCBAJ:, MD BAIlTlWf REIWlILI'l'AUON ASSOC; PBYSICIAlIS OP UIWl MEDICDIB KILTON S. IIBIlSIIEY MEDICAL Cft. KILTON S. IIBIlSIIEY MEDICAL Cft. WDIX 11)4 CIGlIIA COIlRECTIClJ'r LIFE IllS. S'lEVEII E. MOIlGAIIS'rEIII,D.O. LEO D. PARR." T, MD .JOYREll SPOIlTS MEDICDIB BID AID PIWlMACY WEISS HAIlDTS DE1)2-140466 47659-C02 ~~ I~ ." .-1 "~-"< """"" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: WINK (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following dexuments ." thin~ SEE ATTACHED . at MCS GROUP INC., 1601 MARKET ST., 11800. PHILA. ,PA 19103 (Address) You may deliver or mail legible copies of the dexuments 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 dexuments 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: KENNETH S. FAIR. ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHILA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT IDIl ATTORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: /2-/5-00 Seal of the Court rEff 7jQ7) .....- - I I ~~""~~ :!o'-"" EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WINK 104 3400 NORTH 06TH STREET HARRISBURG, PA 17105 RE: 47659 CHRISTINE PARR Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-282036 47659 - L 1 :L '" J ,~" i " "'~..~: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228889 47659 -L12 ~= .1 - ~'- ~~ ~- .MMl>: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICB OF n...rISNr TO SBRVE A SUBPOERA TO PRODUCE DOCtllmlI'rS AND 'l'BIRGS FOR DISCOVERY PORSUAft TO RULE 4009. 21 [ Rote. see enclosed list of locatious ] TO. .JAMIE L. smn.T.RII, ESQUIBB MCS on behalf of DR1IETR S. FAn. ESQUIU 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 8Dd 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 'u:peIlse by comple'ting the attached counsel card and retunling same to MCS or by contacting our local MCS office. nlrl. 12/19/2000 MCS on behalf of ~TB S. PAn. ESQUIBB Attorney for DEPElIDAIlT . CC. KDIIISTII S. PAn. ESQ1JIBB LAR1lY ROTIlVEIIIl - 03125-00368 - HM044705-SV /my questions regapling this matter. coutact THE MCS GROUP IlIC. 1601 IfAIIDt' STREET #800 PlITT AnRI.1'1IIA. PA 19103 (215) 246-0900 DE02-140466 47659-C02 ,.N - * I..-~ -. >>> LOCATIOR LIST <<< RECORDS REQUESTED MEDICAL, BILLIRG, AIID X-RAY(S) MEDICAL, BILLIRG. AIID X-RAY(S) MEDICAL, BILLIRG, AIID X-RAY(S) MEDICAL AIID HOSPITAL BILL X-RAY ONLY MEDICAL, BILLIRG, AIID X-RAY(S) MEDICAL, BILLIRG, AIID X-RAY(S) MEDICAL. BILLIRG. AIID X-RAY(S) MEDICAL AIID HOSPITAL BILL X-RAY ONLY EMPLOYMER'l' IRSmwrcE MEDICAL, BILLIRG, AIID X-RAY(S) MEDICAL. BILLIRG, AIID X-RAY(S) MEDICAL, BILLIRG, AIID X-RAY(S) OTllEa OTllEa I. . -'~" PAGE: 1 LOCATIOR IIAME ORTHOPEDIC IRSTI1'lJTE OP PEIIIIA GOOD HOPE PAMILY PRACTICE cn.. KAGBETIC IKAGIRG CEIITER IIAIIlUSBURG HOSPI'l'AL IIAIIlUSBURG HOSPI'l'AL .rOO S. RYCBA1[, MD HARTKAII BEBABILITATION ASSOC; PHYSICIAlfS OP BEBAB MEDICDlE MILTON S. /lDS1IEY MEDICAL cn" MILTOR S. IIEJlSIIEY MEDICAL Cft" WIRJ[ 104 CIGIIA COHRBCTICUT LIFE INS. STEYER E. KORGARS'l'EIR,D.O. LEO D. pARRRI T., MD .JOYlUll SPORTS MEDICDlE RID AID PIWlHACY WRISS MAJlDTS DE02-140466 47659-C02 ,'-~~ Li --.....1 ~"-', ........."~" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CIGNA (NiUlle of Person or Entity) Within twenty (20) days after service of this subjloena,~ou are ordered by the court to produce the following documents or things: SEE ATTACHED . at MCSGROUP 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 th,. 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: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID t: ATIORNEY FOR: DEFENDANT NAME: ADDRESS: DATE: J:J.. -1.5-00 Seal ofthe Court (Eff. 7/97) ~,-"~- 1_= -",- ~~-':,) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CIGNA CONNECfICUT LIFE INS. 600 E. TAYLOR STREET PO BOX 2546 SHERMAN, TX 75091 RE: 47659 CHRISTINE PARR Any and all claims files. Dates Requested: up to and including the present. Subject: CIJRlSTINE PARR , Social Security #: 175.48.3034 Date of Birth: 11-20-1957 SUIO-282038 47659 - L 12 ,--,' , 1IIiIlIilliirii~~;- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -vs- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228890 47659 -L13 ""'obl.... ,I " '['--- Iil:~,. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S lUID 'l'BINGS FOR DISCoVERY PURSUU'r TO-RULE 4009.21 [ Bote: see enclosed list of locations ] TO: .JAKIE L. SRlU.T.RR. ESQUIRE MCS on behalf of UlftIE'fB S. PAIB.. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frma .the date listed bel_ 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 DO objection is made. then the subpoena may. be served. Complete copies of any reproduced records may be ordered at your expense by cCllllpleting the attached counsel card and returning same to MCS or by contacting our local KCS office. DirE: 12/19/2000 KCS on behalf of llJ51uuua S. PAIB.. ESQUIRE Attorney for DEl'EIIDAR'l' CC : KEBlIE'fB S. PAIB.. BSQUIRB LAlIllY BOTBVBIIR - 03125-00368 - HK044705-SV Any questions regarding this matter. contact 'fBK MCS GBOUP lRC. 1601 MARD'l STREBT #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-140466 47659-C02 "'"','- - -,1_" " "" ~- , >>> LOCATIOR LIS'! <<< RECORDS REQUESTED KEDICAL, BILLIRG, ARD X-RAY(S) KEDICAL, BILLIRG,ARD X-RAY(S) KEDICAL, BILLIRG, ARD X-RAY(S) KEDICAL AND HOSPU'AL BILL X-RAY OBLY KEDICAL, BILLIRG, ARD X-RAY(S) KEDICAL, BILLIRG, AHD X-RAY(S) KEDICAL, BILLIRG, ARD X-RAY(S) KEDICAL ARD HOSPITAL BILL X-RAY OBLY KHPLOYMEIIT INSURAlICE KEDICAL, BILLING, ARD X-RAY(S) KEDICAL, BILLIRG, ARD X-RAY(S) KEDICAL, BILLING, AND X-RAY(S) OTllE1l. OTllE1l. 1,-. - "'~~~h,- PAGE. 1 LOCATION NAME ORTHOPEDIC IRSTITll'lE OP PENNA GOOD HOPE PAHILY PRACTICE cn" MAGNETIC IMAGIRG CJSlIIUIl. HARRISBURG HOSPU'AL HARRISBURG HOSPITAL JOHNS. RYCHAJ[, NO HAB.'l'MAlI REHABILITATION ASSOC; PHYSICIANS OP REHAB KEDICIRB HILTON S. HERSHEY KEDICAL cn. HILTON S. HERSHEY KEDICAL cn., WINK 104 CIGHA CONNECTICUT LIFE INS. STEVEN E. KORGARS'lEIR,D.O. LEO D. FARRIlf.T., NO JOYNER SPORTS KEDICINE RITE AID PHAllMACY WEISS MARKETS DI02-140466 4 7659-CO 2 L-'<);,1ilIiIiIII ~- .-.1 ~~~ ~, H COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: STEVEN.MORGANSTEIN, D.O. (Name of Penon or Entity) Within twenty (20) days after service of this subpoena. J'ou are ordered by the rourt to produre the following documents or things: SEE ATTACHED . at MCS GROUP INC., ~601 MARKET ST., 1/800, PHILA. ,PA 19103 (AddNoal You may deliver or mail legible ropies of the documents or produre things requested by this subpoena. together with the rertificate of rompIianre, to th~ party making this request at the address listed above. You have the right to seek. in advanre, the reasonable rost of preparing the ropies or produdng the things sought. If you fail to produre the documents or things required by this subpoena, within twenty (20) days after its servire, the party serving this subpoena may seek a rourt order rompelling you to romply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST., 19TH FLOOR PHlLA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT 11)" AITORNEY FOR: DEFENDANT NAME: ADDRESS: DATE: J 2-/5-0() 4S Seal of the Court (Eff. 7/97) ,. l......, ~- -<"-'-~J: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STEVEN E. MORGANSTEIN,D.O. 121 GARRISON LANE CARLISLE, P A 17013 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL RECORDS AND NARRATIVE REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175.48.3034 Date of Birth: 11-20-1957 SU10-282340 47659 -- L 13 -~~ I,~ -I~ =~"" ~,o CERTIPICATE PREREQUISITE TO SERVICE OP A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 KCS on behalf of KENNETH S. FAIR, 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. KCS on behalf of DATE: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228891 47659 - L 1 .,. '-=...~." " LJ " ~ ~f,", ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA. TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SII1U.T.RR, ESQUIRE MCS on behalf of KERREYIl S. FAIR, 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 _ived or if no objection is made, then the subpoena may. be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/19/2000 MCS on behalf of KERRE'IB S. FAD., ESQ.UIRE Attorney for DEFERDAIlT cc: KERRETB S. FAD., ESQUIRE LABlI.Y ROTBVEIIR - 03125-00368 - HM044705-SV Any questions regarding this matter, contact THE MCS GROUP IBC. 1601 MARKEr StREET #800 PIJTunELPBlA, PA 19103 (215)246-0900 DE02-140466 4 7659-CO Z ~~ Inil""m " ---.... >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL. BILLDJG. AHD X-KAyeS) MEDICAL. BILLDfG. AHD X-KAY(S) MEDICAL. BILLING. AHD X-KAyeS) MEDICAL AND HOSPITAL BILL X-KAY ONLY MEDICAL. BILLDfG. AHD X-KAY(S) MEDICAL. BILLDfG. AHD J-KAY(S) MEDICAL. BILLING. AND X-KAyeS) MEDICAL AHD HOSPITAL BILL X-KAY ONLY EMPLOYMENT DfSURAlfCE MEDICAL. BILLDfG. AHD X-KAyeS) MEDICAL. BILLING. AND X-KAY(S) MEDICAL. BILLING. AHD X-KAY(S) OTHER 0TBEll. ., ^ ~""'W_~~,._", PAGE: 1 LOCATION NAME ORTHOPEDIC DfSTITUTE 01' PEIlIfA GOOD HOPE FAMILY PRACTICE CrR. MAGNETIC IHAGDfG CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL JOBlf S. RYCIIAX. MD BARTMAN REHABILITATION ASSOC; PBYSICURS OF REHAB MEDICINE MILTON S. IlERSBEY MEDICAL CrR.. MILTON S. IlERSBEY MEDICAL CrR.. VIIIKIOt. CIGIIA CONNECTICUT LIFE DfS. STEVEN E. KORGAlfSTEDf.D.O. LEO D. FAlIlIlO.t.. MD JOYNER SPORTS MEDICINE lUTE AID PHARMACY WEISS KAREBTS DE02-140466 407659-C02 ".' ~ ~I "' -~ " - ~- ~ - -. ~ llJ!I6.! COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS FileNo. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: LEO FARRELL, M.D. (Name of renon or Entity) Within twenty (20) days after servi<e 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., #800, PHILA.,PA 19103 (Addresl) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certifi<ate of compliance, to th" 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 servi<e. 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: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST., 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT IDIl ATIORNEY FOR: NAME: ADDRESS: DEFENDANT BY DATE: _()(PIM~ I~ !)COO Seal of the Court (Eff. 7/97) -"-' -j -, , --~'~"""'- EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LEO D. FARRELL, MD 420 N. 21ST STREET CAMP HILL, P A 17011 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL RECORDS, AND NARRATIVE REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175.48.3034 Date of Birth: 11-20.1957 SU10-282042 4"7659 - L ll. I~~ '~__M"- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228892 47659 -L 1 5 ,~~~ ~ I -~ , I ~ __I -. J,~,,-' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND 'l'HINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE KCS on bebalf of KEHImTH S. FAIR, 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 daynotic!! period is waived or if no objection is made, then the subpoena may.. be s!!rv!!d. COIIIplete copies of any reproduced records may be ordered at your expense by cOlllpleting the attached counsel card and returning same to KCS or by c01lltacting our local KCS office. DATE: 12/19/2000 KCS on behalf of KENNETH S. FAIR, ESQUIRE Attorney for DEFENDAIl'l' CC: KENNETH S. FAIR, ESQUIRE LARRY NOTBWEBll - 03125-00368 - HM044705-SV Any questions r!!gardlng this matter, contact THE KCS GROUP mc. 1601 MAIIKET STREET #800 PDTT AnELPBlA, PA 19103 (215) 246-0900 DE02-140466 4 7659-CO 2 ~. "~ L _1_. ...1 >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLING, AllD X-KAY(S) MEDICAL, BILLIRG, AllD X-BAyes) MEDICAL, BILLIRG, AllD X-BAYeS) MEDICAL AND HOSPITAL BILL X-KAY OBLY MEDICAL, BILLIRG, AllD X-BAyeS) MEDICAL, BILLIRG, AllD X-BAyeS) MEDICAL, BILLING, AllD X-BAYeS) MEDICAL AllD HOSPITAL BILL X-BAY OBLY EHPLOYMEllT OIsmwrCE MEDICAL, BILLIRG, AllD X-KAyeS) MEDICAL, BILLIRG, AllD X-KAyeS) MEDICAL, BILLIRG, AllD X-KAyeS) OTJlEll OTJlEll ,,,, ......" ' " '. ~ iQi..Mc" PAGE, :l LOCATION RAHE ORTHOPEDIC IRSnTUTE OF PEIlIIA GOOD HOPE FAKILY PRACTICE cn. MAGRETIC IMAGIRG CDTEIl HAIllUSBUEG HOSPITAL HARIl.ISBUEG HOSPITAL JOB S. RYCILU, NO IWl'ltWl REHABILITATION ASSOC; PHYSICIARS OF REHAB MEDICIIIE HILTON S. IlEB.SIIEY MEDICAL cn.. HILTON S. IlEB.SIIEY MEDICAL cn.. WIRK 104 CIGRA CORRECTICur LIFE IRS. STEVER E. KORGAIISTEIN,D.O. LEO D. FARRln.T., NO JOYMEB. SPORTS MEDICIIlE RITE AID PIIAIlMACY WEISS MAlIXETS DE02-140466 4 7659-CO 2 ~ I , ~. L'!i!W~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: JOYNER SPORTS (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 thin~: SEE ATTACHED . M MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addn!8s) You may deliver or mail legible copies of the dlKuments or produce thin~ requested by this subpoena, together with the certificate of compU....ce, 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 thin~ sought. If you fail to produce the dlKuments or thin~ 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: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST., 19TH FLOOR PH1LA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID t: ATIORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: _O(Qft\ler J 5: flOOr) ~~~~ Prot!lonotaryf!l!,k, Civ? Division ~/#I~ ~ Deputy . Seal of the Court (Eff. 7/97) ,,' L ~ ,~, -~, EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOYNER SPORTS MEDICINE 3916 TRINDLE ROAD CAMP HILL, PA 17011 RE: 47659 CHRISTINE PARR INCLUDE ANY AND ALL RECORDS, AND NARRATIVE REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48.3034 Date of Birth: 11-20-1957 SUlO-282044 47659 - L1 5 ~~-i CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-228893 47659 -L16 ~~ , L , I '. iJl!ij~I!:-,", ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTEN'1' TO SERVE A SUBPOENA TO PRODUCE DOCOMEN'1'S MID THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE KCS on behalf of IENNETH S. FAIR, 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: 1211912000 MCS on behalf of KEllJlETH S. FAIR, ESQUIRE Attorney for DEFEIIDAIIT CC: KEllJlETH S. FAIR, ESQUIRE LAJlRY NOTllWEllll. - 03125-00368 - HH044705-SV Any questions regarding this matter, contact THE KCS GIlOUP DlC. 1601 IWIl[ET STIlEET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-140466 476S9-C02 I' - I ., RECORDS REQUESTED HImICAL. BILLIlfG. AND X-RAY(S) HImICAL. BILLIlfG. AND X-RAY(S) HImICAL. BILLING. AND X-RAY(S) HImICAL AND HOSPITAL BILL X-RAY OBLY HImICAL. BILLIlfG. AND X-RAY(S) HImICAL. BILLIlfG. AND X-RAY(S) HImICAL, BILLING. AND X-RAY(S) HImICAL AND HOSPITAL BILL X-RAY OBLY EMPLOYHElfT INSUIlAHCE HImICAL. BILLIlfG. AND X-RAY(S) HImICAL. BILLIlfG. AND X-RAY(S) HImICAL. BILLIlfG. AND X-RAY(S) OTHER OTHER J >>> LOCATION LIST <<< -. I~ , , . ~liOlllolil~lilioil*d;,i<, PAGE: 1. LOCATION lfAME ORTHOPEDIC IlfSTI'llITE OF PEHIIA GOOD HOPE FAMILY PRACTICE cn. MAGNETIC IMAGIlfG CEII'lER HARRISBURG HOSPITAL HARRISBURG HOSPITAL JOn S. RYCBAK:. MD BAR'lIWI REHABILITATION ASSOC; 'PBYSICIAlfS OF REBAa H1mICIlIB MILTON S. HERSHEY HImlCAL cn. MILTON S. HERSHEY HImICAL cn. WINlt 104 CIGlIA COlfHECTICUT LIFE IlfS. S'lEVElf E. KORGAlfSTEIN.D.O. LEO D. FARRIlU.. HD JOYllEll. SPORTS H1mICIlIB RITE AID PBAIlMACY WEISS MARKETS DE02-140466 476S9-C02 - J i" ~ -- ~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS FileNo. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: RITE AID (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the <our! to produ<e the following do<uments or things: SEE ATTACHED . at MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Addreso) You may deliver or mail legible <opies of the do<uments or produ<e things requested by this subpoena, together with th.. <ertificate of <omplianc:e, to ihe party making this request at the address listed above. You have the right to seek, in advan<e, the reasonable <ost of preparing the <opies or produdng the things sought. If you fail to produce the do<uments or things required by this subpoena, within twenty (20) days after its servi<e, the party serving this subpoena may seek a court order compelling you to <omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID t: ATIORNEY FOR: DEFENDANT NAME: ADDRESS: DATE: UeMl.kr 15 ..?a:v Seal of the Court (Efr 7/97) ,,,",, I "~ I; ,J '. " i'/(\",_ , EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RITE AID PHARMACY P.O. BOX 3165 HARRISBURG, PA 17105 RE: 47659 CHRISTINE PARR COPY OF ANY AND ALL PRESCRIPTIONS. Subject: CHRISTINE PARR . Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUIO-282046 4765 9 -- L 16 >.. __I -", ~ ..~U( CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA' PURSUANT TO RULE 4009.22 IN THE MATTER OF, COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/08/2001 KENNETH S. FAIR,ESQUlRE Attorney for DEFENDANT DEll-228894 4 76S9-Ll 7 , ~J I '~~!fli,< , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER. ESQUIIlE MCS on behalf of KENNETH S. FAIR. 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: 12/19/2000 MCS on behalf of KENNETH S. FAIR. ESQUIIlE Attorney for DEFENDANT CC: KENNETH S. FAll1.. ESQUIIlE LAl1.l1.Y NOTHWEIIR - 03125-00368 - HK044705-SV Any questions regarding this matter. contact THE MCS GROUP mc. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-140466 47659 - C 0:2 - RECORDS REQUESTED MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAYeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL AND HOSPITAL BILL X-KAY OIlLY MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAYeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL AND HOSPITAL BILL X-KAY OIlLY EMPLOYMENT INSURANCE MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) OTHER OTHER >>> LOCATION LIST <<< - II:'N=~' .~~~ PAGE: 1. LOCATION NAME ORTHOPEDIC INSTITUTE OF PENIIIA GOOD HOPE FAMILY PKACTICE CTa. MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL JOHN S. RYCHAK, MD HARTMAN REHABILITATION ASSOC; PHYSICIANS OF REHAB MEDICINE MILTON S. HERSHEY MEDICAL CTa. MILTON S. HERSHEY MEDICAL CTa. WINK 104 CIGNA COllNECTICUT LIFE INS. STEVEN E. KORGANS'l'EIN,D.O. LEO D. FAllllRT.T., MD JOYNER SPORTS MEDICINE RITE AID PHARMACY WEISS MARKETS DE02-140466 476S9-C02 . ~.....~ . ~~~ "~-.,~~~~... t~. .'~~--- """ ~ " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: WEISS MARKETS (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 . at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addreu) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with th" 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: KENNETH S. FAIR, ESQUIRE 1845 WALNUT ST.. 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT lOll ATTORNEY FOR: NAME: ADDRESS: DEFENDANT DATE: [) toe'" b<r- /5; ;)006 ~~T:~~ ProthonotuyfCI Ivil Division ~/Ll~hJ'n Deputt Seal of the Court (Eff 7'/<r1) I. L ~~l,rnt.~: l' " EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WEISS MARKETS CAMP HILL, P A RE: 47659 CHRISTINE PARR COPY OF ANY AND ALL PRESCRIPTIONS. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20.1957 SUIO-282048 4765 9 - L 1 -7 .. "'''~.~l!!l~~~~@o;;i1\1:iB,ii>!'',~;\ci~'i!ii}j~'';;''-'mM )..11"">",,,,"<. _ ,.",> ".,"",,,,,.,.,..,,,~ c ,~~ . ~'~ _ ,'= , , '~'.~.4'c;'.k- " ~,,~ ',C<' ~_.,- ~-" ,,~-- ;~~--_.. '-""""'~i"""""~ ,'",?<- ~~ lJr; S2 ~"~ 6~l-- ~.<' ~(~) 0(-: -",>C: 2: ~!. '. "" ~~'" ~ \." G ~ -:" i " ~ !_~ ".,' r~:? ':.JI) CJ . .'...'-~ ~ , ~. 'iIl.llli:')' --.,.; CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 ~I S o~eh:r1Df ~~ NNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211383 4765 9 - L::1. 8 l..h """,,:1 I. " .1' . '.....--. lli',;.;iilw.!l1ofl1!,:. , ^ . , '-'. '-', ".UV.,., r'd'i:jtl I I ~ (aiO!i) QD 1601 Markel Slreet, Suile 800, Philadelphia Pennsylvania 191113 (215) 246 . (\9(\(\ Fax Number (215) 246 . 1)')5') URGENTmU URGENTmn URGENTmn JANU<\RY 16. 2001 alRISTlN!: ~ PARR Vs l<EYS'l1:fE SPINE tmml., m::., ET AL MI\RSlIIIlL, IEmlEY, ET JiL lCDIElH S. FAIR. ~ - (215) 575-0856 oe have been ,...,.....ted by the aIJove-mlfttialed c:o.n;el to obtain material aI an expedited basis fran the be.la< listed custodians. In order to cCllply with this tecpeSt loll! n'ust have your s~um indicating that }'tll 'WIIive the t:wBIty-day not.:Ice pedal provided in Rules 4009.21 an:!. 4009.22. Pleue fax this fOlJl\ to us iIml;diately at (215) 246-0959 with your siRnatw:e so that we nay CCtlply with this J:'eCl.lOst. Ywr coopetatim I01l.d be gr:eatly awteeiated. Sincerely, SAKINAIl ma;: OJStodians : [ Note; see ea:loged list of locatials ] --,. ~ JtlMIE L. SllWllR. ) /. 1 .... ~.... '"""" '" _. },,/o / "",,". ",,,k "'_ I do not agree to.w.ve rule, IBte, RRWl-13l777 4 7659-CO 1. ~,f ~ L. ,', I I -,<'- ~ '~'-""""-""'..6. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTOIlE SP1IlE CENTER, !!IC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE KCS on behalf of KE!IIlETH S. FAIR, 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: 01/16/2001 MCS on behalf of KE!IIlETH S. FAIR, ESQUIRE Attorney for DEFElIDAIlT CC: KE!IIlETH S. FAIR, ESQUIRE LARRY NOTIIWEHR - 03125-00368 - HM044705-SV Any questions regarding this matter, contact THE KCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l42441 47659-COZ .~--~"- i J . I I. L..=~,,"" I >>> LOCATION LIST <<< -I. __~.'"<t. &:iJ -Ill:",," PAGE: 1 RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL AND HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, ANDX-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAyeS) MEDICAL, BILLING, AND X-RAY(S) INSURANCE LOCATION NAME HEALTHSOUTH REHAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR MICHAEL E SCHATMAH PROSTHETIC ASSOCIATION MAGNETIC IMAGING CENTER PHYSICIAN'S IMAGING CENTER QUANTUM IMAGING , THERAPUTIC DR. Z LOTOFP PRUDENTIAL DISABILITY HNGHT. DE02-l42441 47659-CO? L. - "~ I ~~"'''''"''''~''-j$\.- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. OO-OhRR7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HEALTH-SOUTH REHABILITATION CENTER (Name of Person or Entity) Within twenty (20) days aftel' service of this subpoena, you are ordered by the court to produce the following documents or things: ~l<l< A '1"1' A "l>l<n at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) 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 producinl{ the things sought. If you fall to produce the documents or things required by this subpoena within twenty (20) d~ after its service, the party serving this subpoena may seek a court order compelling you to comply with it. TIDS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: KF.NNF.TH S. FATR l<~QnTRl< ADDRESS: 1845 WALNUT ST. 1 llTH VLOOR PHlLA. .PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT 10# ATTORNEY FOR: DF.Fl<NnANT DATE:--JIU'.M/'~ /% ~tPI Se of the Court BYTH~OURT: I? ~ 5/ 'caW . ~ ' ProthonotaryjCl rk, Civil Division -tfJeutJ 4 '~A4l ~ Deputy I (ErT797) ~. ,c. . L . ~ J I ^ ~ 1IIIIiIiIIillIi~:--- !JiOfl 'i~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB 920 CENTURY DRIVE MECHANICSBURG, PA 17055 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatmenl. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175.48.3034 Date of Birth: 11.20.1957 SUlO-285384476S9-L1B ;'- ~~I '. " '''~",I"t. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211384 47659 - L:1- 9 ,,'. .'. L ~~*j, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -YS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, DlC., ET AL NOTICE OF IN'l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHRT.l.RR, ESQUlHE KCS on behalf of KENNETH S. FAIR, ESQUlHE 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 i. waived or if no objection is made, th!!n the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completin& the attached counsel card and returning same to HCS or by contacting our local KCS office. DATE: 01/16/2001 HCS on behalf of KENNETH S. FAIR, ESQUIU Attorney for DEFENDo\JIT CC: KENNETH S. FAIR, ESQUIRE LARRY NOTHWEBR - 03125-00368 - HM044705-SY Any questions regarding this matter, contact THE KCS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 1910) (215) 246-0900 DE02-l4244l 47659 -C02 ...... ."~"' ~I >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLING, AND X-KAY(S) MEDICAL AND HOSPITAL BILL X-KAY ONLY MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) INSURANCE '1., .~. ~ "jS"'I~<\ PAGE: 1 LOCATION NAME HEALTRSOUTB REIIAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR KICIIAEL E SCBATMAN PROSTHETIC ASSOCIATION MAGNETIC IMAGING CENTER PHYSICIAN'S IMAGING CEIITEII. QUANTUM IMAGING (, TBERAPtl'l'IC DR. Z LOTOFF PRUDENTIAL DISABILITY MNGM'f. DE02-14244l 47659-COZ L~~~, ~ , . " "0 "" ~'"""n'/' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. 00-06887 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SF.F. ATTAr.H1':n at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) 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) d&.li'1l &J't.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: KENNETH S. FAIR. F.SOUTRF. 1845 WALNUT ST. 19TH FLOOR PHILA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: J/1//!~ It? pml r, Se of the Court BY THE CO *-(7~.k , Prothonot jClerk. Civil Division :t/lL~#f4~ I Elf 797) .~,' -" L-.~ ,-.' ". i'llIlllt~!,~ EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 N. 21ST ST, CAMP HILL, P A 17011 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relaling to any examination, consultation, care or treatment of patient. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-285386 47659 -L19 . I _ I, -.-J "-'= ......~-Ht;; CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -vs- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211385 47659 - L 2. 0 ...........~ ~l """,,,,~~.'~' t'I<lI!iU~ 'l!3W--' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS~ CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC.. ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE MCS on behalf of KENNETH S. FAIR, ESQUIU intends to serve a subpoena identical to the one that is attached to tbis aotice. You have twenty (20) days from the date listed below in vb Idl to' I I. of record and serve upon the undersigned an objection to the sub~. I' tbe twenty day notice period is waived or if no objection is made, th_ t be ....na may be served. Complete copies of any reproduced records may be 0'''''' at your expense by completing the attached counsel card and return I.. ._ to ICS or by contacting our local MCS office. DATE: 01/16/2001 MCS on behalf of KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT CC: KENNETH S. FAIR, ESQUIRE LARRY NOTHWEIIR. - 0111\."'" - lMMun.n Any questions regarding this matter, c_t act THE MCS GROUP INe. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l42441 47659-C02 --"^.."'~. ~ ~I .,~. .. ,..~. >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLING, AND X-KAY(S) MEDICAL AND HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-KAY(S) MEDICAL, BILLING, AND X-KAY(S) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) INSURANCE ",. PAGE: LOCATION NAME IlEALTHSOUTH REHAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR MICHAEL E SCHATMAN PROSTHETIC ASSOCIATION MAGNETIC IMAGIlfG .CENTER PHYSICIAlI'S IMAGING CENTER QUANTOK IMAGING , THERAPU'lIC DR. Z LOTOFF PRUDENTIAL DISABILITY MNGMT. DE07.-142441 4 7659-CO:7- ~j!<br 1 ," ~.. . I '~ .~~~ "~'-. ~'.'rlM" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. 00-06RR7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: ~RR A'1''1'Ar'''Rn at MCS GROUP INC., 1601 MARKET ST., #800. PHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this sulllpoena. together with the certificate of compliance. to the party making this request at the address 1 istee! 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) day. atter its service. the party serving this subpoena may seek a court order compelling you to comply wHh it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: KENNF.TH S. FAIR. 1<:SQJJTRR 1845 WALNUT ST. 19TH FLOOR PHILA. .PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID# ATTORNEY FOR: DF.FF.NnANT DATE: ftA1.1AAAy' Ii" ~cJ{J/ u Seal of the Court :P/~;~T:4 ~ , prothonotary~k, Civil DiviSIOn ~ljn Ilf ~4~ Deputy (Flf 7 97) L...._" . ~~. ",1_ I ~ , : "- ..".-~",,"Ylli:, EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 N, 21ST ST, CAMP HILL, PA 17011 RE: 47659 CHRISTINE PARR Any and all X-Rays pertaining to palient. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-285388 47659 -L20 L~ "."L Ii "I - ""'" 111!l",\~~;' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT .OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211386 47659 -LZl I .~,L ""..1 ~ . ,-,tlL" CO~ONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COMMON PLEAS PARR TERM, -YS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAli'l' TO RULE 4009.21 [ Note, see enclosed list of locations ] TO, JAMIE L. SHELLER, ESQUIRE MCS on behalf of KENNETH S. FAIR, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll 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 retuming same to MCS or by contacting our local MCS office. DATE, 01/16/2001 MCS on behalf of KENNETH S. FAIR, ESQUIRE Attomey for DEFENDANT CC, KENNETH S. FAIR, ESQUIRE LARRY NOTHWEBR - 03125-00368 - BM044705-SY Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-14244l 476S9-C02 ,,~~ "~, >>> LOCATION LIST <<< ItECORDS ItEQUESTED MEDICAL, BILLING, AHD X-KAY(S) MEDICAL AHD HOSPITAL BILL X-KAY ONLY MEDICAL, BILLING, AHD X-KAyeS) MEDICAL, BILLING, AHD X-KAyeS) MEDICAL, BILLING, AHD X-KAY(S) MEDICAL, BILLING, AHD X~KAY(S) MEDICAL, BILLING, AHD X-KAyeS) MEDICAL, BILLING, AHD X-KAyeS) INSURANCE '~ """ !~,.,-.,,- PAGE: 1. LOCATION !fAME BEALTBSOUTB llEBAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR KICIIAEL E SCBA'l'HAN PROSTHETIC ASSOCIATION MAGNETIC IMAGING CENTER PBYSICIAlII'S IMAGING CEIlTER QUAIlTllH IMAGING , TBERAPUTIC DR. Z LOTon PRUDENTIAL DISABILITY HlIGMT. DE02-l42441 47659-CO.2 c " " , , ->.\1" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. OO-.06flfl7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. MICHAEL SCHATMAN (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: q"" A'I''I'u'''''n at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You maw 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 producinl{ the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days atter its service, the party serving this subpoena may seek a court order compelling you to comply Wlth It. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: KF.NNF.TH S. J1ATR J1SQITTRR ADDRESS: 1845 WALNUT ST. 1 qTH J1!.OOR PHILA. .PA lQl01 TELEPHONE: 215-246-0QOO SUPREME COURT ID# ATTORNEY FOR: DRJ1RNnANT DATE: d /.1/YlJMV2~ I~ 201/ Seal of he Court BY TH~OURT: If! .I. /r/ ~ - i1lai! . ProthonotaryjC rk, Civil Division 0)~~;11)~&~ Depu y I Elf 7 97) .' ~ . ~ ,I ~ "':',,,.."r~' ..~,.-, EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR MICHAEL E SCHATMAN REHAB OPTIONS 2645 N 3RD ST ST 460 HARRISBURG, PA 17110 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten noles, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-285390 47659 - L 2 JL ,/~.~ - 1- I~ .. l%J~ ~~'~:;G;~ ," CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -vs- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a .prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211387 47659-L22 _L" ,[ - -, ij"*,,' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS .FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE MCS on behalf of KENNETH S. FAIR, 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: 01/16/2001 MCS on behalf of KENNETH S.FAIR, ESQUIRE Attorney for DEFENDABT CC: KElQIETH S. FAIR, ESQUIRE LARRY NO'lBWEllR - 03125-00368 - BM044705-SV. Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MAllXET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l42441 47659-C02 ,~- -~.,- -~"' .1 >>> LOCATION LIST <<< L -~irIIlrlIIll!iII~M~^ PAGE: 1 RECORDS REQUESTED MEDICAL, BILLING, AND X-KAYeS) MEDICAL AND HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-KAyes) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE LOCATION NAHE HEALTHSOUTH REHAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR MICHAEL E SCHA'nWf PROSTHETIC ASSOCIATION MAGNETIC IMAGING CENTER PHYSICIAN'S IMAGING CENTER QUANTUM IMAGING 5. THERAPlIUC DR. Z LOroFF PRUDENTIAL DISABILITY MNGHT. DEOZ-142441 47659-C02 "-~" - I", '~'" ~ ..~~, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. 00-06RR7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR PISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PROSTHETIC ASSOCIATION (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: ~l<l< A'I''I'Arlmn at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) 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 producioK the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) day. after its service, the party serving this subpoena may seek a court order compelling you to comply Wlth it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: KENNF.TH S. FAIR. F.SQlITRl< 1845 WALNUT ST. 19TH FLOOR FHlLA. .FA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID# ATTORNEY FOR: nF.1'F.NnAN'l' DATE: f/YIJ'UI1~ II: ;9Cl'J1 Se of the Court BY THE COURT: -tfl. j;/~~~ '~1l: rothonotary/Cle . Civil Division -tJ,J/~~4d-f!9 Deputy I Hr 7 97) ,,' - "" J'_ ' , . ~~lIl\Il~-_ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PROSTHETIC ASSOCIATION 3514 TRlNDLE RD. CAMP HILL, P A 17011 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-285392 47659-L22 .II I ~ih,'. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC.. ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties ~ave waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211388 47659-L23 ~ L -" . '-~ ,to ~ , I ~ I, ~ ':""';L.l!ii&,IIMtli1-1(\ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMKON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF IN'l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMRN'l'S AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SIIELLER, ESQUIRE KCS on behalf of KENNETH S. FAIR. ESQUllI iJltends to serve a subpoena identical to the one that is attached to t_ls DOtice. You have twenty (20) clays from the date listed below in vb lela to f 11. of record and serve upon the undersigned an objection to the subpo.as. If t-' twenty clay notice period is waived or if no objection is made, tb.. t-' s"~J>>na may be served. Complete copies of any reproduced records may be 0'''''' at your expense by completing the attached counsel card and return 1.. ._ t.. ItCS or by contacting our local KCS office. DATE: 01/16/2001 KCS on behalf of KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT CC: KENNETH S. YAIR, ESQUIRE LARRY NOTIIWEIIR - Ol\n~..,.. - 1MD441.~-" Any questions regarding this matter, c.-tact THE KCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l4244l 47659-C02 ~-,. >>> LOCATION LIST <<< "' ~~-~~''''~_ft 1&1',*", j PAGE: 1 RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL AND HOSPITAL BILL X-RAY ONLY MEDICAL. BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL. BILLING, AND X-RAY(S) INSURANCE LOCATION NAME HEALTHSOUTH REIIAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR MICHAEL E SCHATMAN PROSTHETIC ASSOCIATION MAGNETIC IMAGING CENTER PHYSICIAN'S IMAGING CENTER QUANTUM IMAGING , THERAPUTIC DR. Z LOTOFF PRUDENTIAL DISABILITY MNGMT. DE02-142441 4 7659-CO 2 . . --~~ '~.-"'~~; EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17055 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-285394 47659 - L 2 :'\ ....-.-.... , ~I I I - llti: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -vs- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211389 47659-L2.4 1_ "-"<.. ~- , . . ---,-~" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE KATTER OF: COURT OF COMMON PLEAS PARR TEllM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE KCS on behalf of KENllETH S. FAIR, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOJll 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 KCS office. DATE: 01/16/2001 KCS on behalf of KENNETH S. FAIR. ESQUIRE Attorney for DEFE1lDANT CC: KENllETB S. FAIR, ESQUIBB LARRY NOTIIWEIIR - 03125-00368 - BK044705-SV Any questions regarding this matter, contact THE KCS GROUP INe. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l42441 47659 - C 0:2 --~ ~~ -, 1- = ., .~ >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL AND HOSPITAL BILL X~RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE I . . ~'~.""*". PAGE: 1 LOCATION NAME BEALTBSOUTB REHAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR MICHAEL E SCBATHAH PROSTHETIC ASSOCIATION KAGIlETIC IMAGING CEH'rER PBYSICIAH'S IMAGING CENTER QUANTUM IMAGING {, TIIERAPUTIC DR. Z LOTOn PRUDENTIAl. DISABILITY HNGHT. DE02-l42441 47659-C02 L ~ I ~, "'. .'~"'"-~~'~,'~ii ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. 00-06887 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PHYSICIANS IMAGING CENTRAL (Name of Person or Entity) Within twenty (20) d:tys :tfter service of this subpoena. you are ordered by the court to produce the following documents or things: ~FF A '1"1' A rHFn at MCS GROUP INC., 1601 MARKET ST., .~()O. I'HIl..A. ,PA 19103 (Add,.....) You may deliver or I!llIillegible copies of the docu menta or produce things requested by this subpoena, together with the certificate of compliance. to the part., m&lUnc this request at the address listed above. You have the right to seek in advance the reasonable ....., or preparing the copies or producing the things sought. If you fail to produce the documents or things noqUl.... tJy thia subpoena within twenty (20) days after its service. the party serving this subpoena may _II " ",...r'\ order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST 0" n... FOLLOWING PERSON: NAME: KENNETH S. FAIR. F.SOUTRF. ADDRESS: 1845 WALNUT ST. 19TH FLOOR PHlLA. ,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: j~ J:r 9d:?1 (/ Se of the Court HY TH It COURT: .7 <vll.} PT<)thonotary lerk. Civil Division ~):ua 4f) #~ Deputy . - (E:ff.7/97) , . " I '~~.~,. "'lliit'i:_ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PHYSICIAN'S IMAGING CENTER 4349 CARLISLE PIKE CAMP HILL, PA 17011 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or Ireatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-285396 47659 - L 2,4 - .__,1 .li>Mi'''"', CERTIFICATE . PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -vs- CASE NO: 00-06887 KEYSTONE SPINE CENTER. INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DATE: 01/16/2001 DE12-211390 47659-L25 - ,,,," ~ J ~ '. _J ,,~O' , ~ '" }'M'\:; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE MCS on behalf of KENNETH S. FAIR, 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 MCS or by contacting our local MCS office. DATE: 01/16/2001 MCS on behalf of KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT CC: KENNETH S. FAIR, ESQUIRE LARRY NOTBWEBR - 03125-00368 - BM044705-SV Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l42441 47659-C02 ~~~~ > = >>> LOCATION LIST <<< .. L.J "". ,I, .,,..; '~A""~~~, PAGE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL, BILLING, AND X-RAY(S) MEDICAL AND HOSPITAL BILL X-RAY OIlLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE HEALTHSOUTH REHAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR MICHAEL E SCHATMAN PROSTHETIC ASSOCIATION MAGNETIC IMAGING CENTER PHYSICIAN'S IMAGING CENTER QUANTUM IMAGING , THERAPUTIC DR. Z LOTOn PRUDENTIAL DISABILITY HNGHT. DE02-l42441 47659-C02 ~, . , I ~ ^ i ""-~'9"'~~WB., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. OO-OliAA7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:QUANTUM IMAGING (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: SFF A'l"rArHFn at MCS GROUP INC., 1601 MARKET ST.. "HOD. PHIlJ.. ,PA 19103 (Add_l You may deliver or mail legible copies of the docurDAtnu or produce things requested by this subpoena, together with the certificate of compliance, to the par1 J ....&ing this request at the address listed above. You have the right to seek in advance the rea80n~ "'0.' of preparing the copies or producing the things sought. If you fail to produce the documents or things ...-qw"'" by tbis subpoena within twenty (20) da~r8 after its service, the party serving this subpoena may __ . "'...'" order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST or TH. POILOWING PERSON: NAME: KENNETH S. FATR. F.SQ1TTRF ADDRESS: 1845 WALNUT ST. 19TH PHlLA. .PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT 10# ATTORNEY FOR: DF.FF.NT1ANT FT ,OOR DATE: ,-r:;(J/ wrV /!; Pall Seal of the Court B~;~~:.R~ . . L I~k C'vilD' , . Prothonotary: . I IV1s1on -/.:)~l/"q -~ ~ Deputy (Im.7/97) , dl~ ~. " ,'_.'< _'." ., '.,;~~:~~ EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERAPUTIC 3508 TRINDLE ROAD CAMP HILL, PA 17011 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consullation, care or treatment. Dates Requested: up to and including the present, Subject: CHRISTINE PARR , Social Security #: 175-48.3034 Date of Birth: 11-20-1957 SUlO-285398 47659 - L Z ~) I. ~, ,..hr, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT .TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-21139l 47659-LZ6 "- I ~ ..J '. I .1 ,,,;... -.rJ!i!W:" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COHMON PLEAS PARR TERM, -YS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AI. NOTICE OF INTBN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE '4009,21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE MCS on behalf of KENNETH S. FAIR, 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 i. 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 completinl the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/16/2001 MCS on behalf of KENNETH S. FAIR, ESQUIU Attorney for DEFENDAIIT CC: KENNETH S. FAIR, ESQUIRE LARRY NOTIIWEIIR - 03125-00368 - BM044705-SY Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19101 (215) 246-0900 DE02-142441 47659 - CO :Z ,. .'1 >>> LOCATION LIST <<< . . ~~ '-~...... -'~--rl1li~j!\;ii:!lll'>' PAGE: 1 RECORDS REQUESTED LOCATION IIAHE MEJ>ICAL, BILLING, AND X-RAY(S) MEJ>ICAL AND HOSPITAL BILL X-RAY ONLY MEJ>ICAL, BILLING, AND X-RAY(S) HEllICAL, BILLDfG, AND X-RAY(S) MEJ>ICAL, BILLING, AND X-RAY(S) HElllCAL, BILLDfG, AND X-RAY(S) MEJ>ICAL, BILLING, AND X-RAY(S) MEJ>ICAL, BILLING, AND X-RAY(S) INSURANCE BEALTBSOUTB REHAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR .HICBAEL E SCBA'l'MAII PROSTHETIC ASSOCIATION MAGNETIC IMAGDfG CENTER PHYSICIAN'S IMAGING CENTER QUANTUM IMAGING " TIlERAPUTIC DR. Z LOTOFF PRUDENTIAL DISABILITY HNGMT. DE02-l4244l 47659-C02 ~ I'.. ~r" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. OO-OfiRR7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: CUSTODIAN OF RECORDS FOR: DR. Z. LOTOFF (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: ~1<1< O'1''1'or''1<n at MCS GROUP INC., 1601 MARKET ST., '800. PHlLA.,PA 19103 ( Add...., You IIl83 deliver or mail legible copies of the documenu or produce things requested by this subpoena, together with the certificate of compliance. to the part, -."'ng this request at the address listed above. You have the right to seek in advance the reasonabM .,.... of preparing the copies or producing the things sought. If you fltil to produce the documents or things """,1&1,,",,, by Ulia subpoena within twenty (20) d~rs after its service. the party serving this subpoena may __ . """'" order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF nc. P'OLLOWING PERSON: NAME: KENNF.TH S. FAIR. 1<SQITTR1< ADDRESS: 1845 WALNTIT ST. 19TH FLOOR PHILA. .PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID# ATTORNEY FOR: nF.F1<NT1AN'I' DATE: l~,'1lA.arV If? .9001 Sial of the Court BY .Tl)fo COURT: .j.( .(('.m 1fl ~ PTothono lerk. Civil Division .f',~Na /JtlU~ Deputy (l~ff. 7/97) I~ 1_ . ~"";~~ml!l!:',J)M, ' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. Z LOTOFF 3600 TRINDLE RD. CAMP HILL, PA 17011 RE: 47659 CHRISTINE PARR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating 10 any examination, consultation, care or trealmen!. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-285400 47659 - L Z 6 ,- -, "I , ;;, .~ ~ ~ ~i0~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 01/16/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DE12-211392 47659-L27 .~.' , " ~. 1"-' - .."''; '. ''l:I~,,__ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE KATTER OF: COURT OF COMMON PLEAS PARR TEllH. -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER. ESQUIRE MCS on behalf of KENNETH S. FAIR. 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: 01/16/2001 KCS on behalf of KENNETH S. FAIR. ESQUIRE Attorney for DEFENDANT CC: KENNETH S. FAIR. ESQUIRE LARRY NOTBWEHR - 03125-00368 - BK044705-SV Any questions regarding this matter. contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-l42441 47659-C02 ~.~- - ,~ . - >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLING, AND X-KAY(S) MEDICAL AND HOSPITAL BILL X-KAY Ony MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) MEDICAL, BILLING, AND X-KAyeS) INSURANCE .-1- _~ti~Bjj}:." PAGE: 1 LOCATION IWfE BEALTBSOUTB REHAB HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL DR MICHAEL E SCBATMAII PROSTHETIC ASSOCIATION MAGNETIC IMAGING CERTEll PHYSICIAN'S IMAGlNG CENTER QUAIlTOM IMAGING (, TBERAPUTIC DR. Z LOTOFF PRUDENTIAL DISABILITY HNGMT. DE02-l42441 47659-C02 ...,'d' "b..~.~ ,~~I ~ - , .1 ~.. "'n-:;-i1~",i' COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND PARR VS KEYSTONE SPINE CENTER, INC., ET AL File No. nn_n;;AA7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PRUDENTIAL INSURANCE CO./DISABILITY MANAGEMENT SERVICE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, YO" are ordered by the coart to produce the following documents or things: ~~~ . '1''1'' ('''~n at MCS GROUP INC., 1601 MARKET ST., '800, PHlLA.,FA 19103 (........--) You may deliver or mail legible copies of the d~.. tW produce things requested by this subpoena. together with the certificate of compliance, to the puty _aW"1 thie request a.t the address listed above. You have the right to seek in adva.nce the reS*)...... ... 01 preparing the copies or producing the things sought. If you fa.Jl to produce the documents or things ~ .., \JUs subpoena within twenty (20) daiYs after its service. the party serving this subpoena may -.II . .... order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUBIIf ~ T1III fOLLOWING PERSON: NAME: KF.NNF.'T'H ~. 'FATR F.~QTTT1H;' ADDRESS: 1845 WALNUT !':T. 1 qTH FT,OOll PHlLA. .PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID# A'ITORNEY FOR: n~FF.NT1AII1'1' DATE:Ja.()\A~ /8', [}tYJ / Se of the Court .. BY TIll COURT' ,jI,/'hliA "-? )I~ Prothonot Clerk, Civil Division ;JJ~ 111/- ~~CPf Deputy (Eff, 7/97) ....,. ..~" ~I~~~ . ~.l_ .,1 .1" , .~" ~ ,'",,' -" I " , &:"~, EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PRUDENTIAL DISABILITY MNGMT. PO BOX 2300 P ARSIPP ANY" NJ 070549857 RE: 47659 CHRISTINE PARR Any and all claims files. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 5UlO-285402 47659 - L 2 7 ~~Ji~.u'-<'--""';''''''' ~'"Wi;;!la;ili,--ii~~llil'J~~:i""4""']It.r,!;;JirS,n,!,,,">If.,,'l:II;,i";~:offi!tiill-~~~\i!lm~iili~i~'1~""- -,-" ""~,, P'~"" "",~. ,~~~ . " ~-,--- ~ I ,<",:t'f..-, .,- ., "" -, ~ ~ ~ - -' > ~ lJIi Ilii_- ~~' '.-.-.". ... - () <:::) 0 c $: ~Tj '~o:: '- 5Prn ::;:-n ?::~i :!:! ::c z .\ 2e" r" f-~ (/) ,'- \D ~.~ -<2 t<o v ::;:;;0 :3: 2C '~C5 ;i>' c ~ Om ~ >:::> ~ ...- :b -< , ~I ~ 1,- .hI ,~-~ ~,-~"'~,:.~-" i! , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER. INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 03/27/2001 ~~~",beJa~ .of ~~{.~ESQUlRE Attorney for DEFENDANT DEll-242367 47659-LZe ~~ 'I -'- '0 ~, - .-"0.... , ""ms..liIiI.iihoill''tl'h , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS P AllR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NO'lICB OF IIlI'J:1Slft' 'l'O SBRVE A SUBPOBRA 'l'O PRODUCE DOCtJlIBIRS AND TBINGSPOR DISCOVERY PURS1JAIft 'l'O RULE 4009.21 [ Note: see enclosed list of locations) TO: JAMIB L. SII'RJ..1.1lIIs BSQUlU _::;:.- HeS on behalf of. KD!fB'J'II. S. . PAIlle BSQUIU intends to serve a subpoeD& identical to the one . that is attached to this Dotice. Yon have twnty (20) days fraa the date listed bel_ in whic:h to file of record lIIlll serve upoD the IlDdersiped an objection to the subpoeDa. If the twnty.day notice period is waived or if DO objection is made. then the subpoena may be served. ClDplete copies of any reproduced records may be ordered at your espllll8e by clDpleting the attached c01lJ18el card lIIlll returning s_ to MeS or by contacting our local HeS office. nATE: 03/06/2001 HeS on behalf of KEllllBTB S. PAIl. ESQUIU Attorney for DUB1IDA1ft CC: ILlUIIVitlt S. PAIlle BSCl1JID LADY 1ICb...... - 03125-00368 - BM044705-SV Any questions regarding this mat.t.er. cont.act TBB HCS GIlO1JP INC. 1601 IWlD'f SftBI'f '80ct PIIILADBLPBIA. PA 19lGS (215) 246-0900 DE02-146648 47659-C02 , RECORDS REQUESTED MEDICAL , BILLIBG MEDICAL , BILLIBG MEDICAL , BILLIBG O'l'llEll O'l'llEll O'l'llEll MEDICAL AIm BOSPl'1'AL BILL MEDICAL , BILLING : 1.- >>> LOCATION LIST <<< PAGE: LOCATIO. IfAMB BEALTHSOUTII RIBAB DR. WlLLIAII BUSH .rOD VICKORY. H.D. BA1IJtISBUIG PIfABIIACY RITE-AID CORPOIA'fIOIf CVS PAA-aCT OSTEOPATHIC HOSPl'1'AL DR. JOD GOLDIWI ~- "" ,,~,~~ 1I~,~ 1 --~~~ -......;: DE02-146648 476S9-C():2 ~, '.oJI 1,,- "' ", ~'="iil&, COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERL.~'l'D PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUAA"T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: l1EALTH SOUTH (Name of Pet'Son or Entity) Within twe",! (20) days after service of this subpoena. you are ordered by th.. court to produce the following docurr,ents or things: at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You may delinr 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 ha\'e the right to seek, in ad,'once, the reasonable cost of preparing the copies or producing the things sought. If you fail to ;r.oduce the documents or things required by this sub~ witJo.in twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Sli'BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: Ki1\Th1li'TU c: 1+'A Tll r R~QIJTRR ADDRESS: 1845 WALNUT ST., 19TH FLOOR 'PHTTA .'PA lQl01 TELEPHOSE: 215-246-0900 SUPREME COURT ID #: ATTOR.'-:EY FOR: DEFENDANT DATE: (Yl;U)~-( :J .:l ev<./ , ~ Seal of the Court {Elf. 7/97) +- EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB 920 CENTURY DRIVE MECHANICSBURG, PA 17055 RE: 47659 CHRISTINE PARR Any and all records, correspondence, files and memorandums, handwrilten notes, billing and payment records, relating to any examinalion, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175.48.3034 Date of Birth: 11-20.1957 . , I, n" 'i, ; "1 "--''''''-- "" '. -. -- 1ll!~~~' -..-: 5UlO-2934l4 47659 -LZ8 I" ,"-'J "._->., '-""cd, iln-h' , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and 'things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 03/27/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-242368 47659-L29 .~ "I _, '''- k~-' ; - ,,"',~- ~~ >. ~- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NO'l'ICE OF I)1"J:JS1\IT TO SERVE A SUBPOENA TO PRODUCE DOCtJJIEIITS AND THINGS FOR DISCOVERY PURSUANT TO RULE 40U9, 21 [ Note: see enclosed list of locations.] TO: JAMIE L. SART.T.D. ESQUIRE MCS on behalf of KEllBETB S. FAIll. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll 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 8Zpense by completing the attached counsel card and retuming same to MCS or by contacting our local KCS office. ':........--f DATE: 03/06/2001 MCS on behalf of KEllBETB S. FAIll. ESQUlU Attomey for DDEHDAlrr cc: KEllBETB S. FAIIl. ESQUlU LARllY NOTaIlAII.' - 03125-00368 - BM044705-SV Any questions regarding this matter. contact TIlE MCS GIlOUP IRC. 1601 HAllET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-146648 47659-CClI2 RECORDS REQUESTED MEDICAL , BILLING MEDICAL , BILLING MEDICAL , BILLING OTHER OTHER OTHER MEDICAL AlO) HOSPITAL BILL MEDICAL , BILLING 1-. >>> LOCATION LIST <<< I ^. PAGE: LOCATION NAMB BEALTHSOtl'lll IlEIIAB DR. WILLIAH BUSH JOB VlCKOR.Y, M.D. BARR1SBUR.G PBAllKACY RITE-AID CORPOIlATlOII CVS PBAllKACY OSTEOPATHIC HOSPITAL DR. JOB GOLmWI :!i!.liP~ 1 -~~- -.;.,,; DEOZ-146648 47659-C02. 'I -I, < ~"J '~~';,N' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLA.."m PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMThiS OR THINGS FOR DISCOVERY PURSUA.."-i TO RULE 4009..22 TO: CUSTODIAN OF RECORDS FOR: DR. WILLIAM BUSH (Na.me of Penon or Entity) \-\~ithin tlolt'e~. (20} days after service of this subpoena. you are ordered by the court to produce the following documents or things: -. C MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addr..s) at You may deiiver or mail legible copies of the documents or produce things requested by this subpoena. together with the certificate of compliance, to the patty making this request 0,\ the oddress listed above. You hon the right to seek, in ad...nce, the ",..onable cost of preparing the copies or producing the things sought. II you fail to ?"oduce the documents or things required by this subpoena. within twenty (::0) cays after its sen'ice. the party sen'ing this subpoena may seek a court order compelling you to comply with 1'_ THIS Sl13POENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: Kil-ThT17'T'T-1 c: 1i'ATR. F.~OTTTRF. ADDRESS: 1845 WALNUT ST., 19TH FLOOR 1'1Hl ~ l'A lQ10, TELEPHO:\E: 215-246-0900 SUPREME COURT ID It: ATIOR.'\EY FOR.: DEFENDANT DATE: mil""''' ::J ':1 rv-./ . Division Seal of the Court i~~::. 7,'97'1 - ~" 'L ~ l," ~ . EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. WILLIAM BUSH DAIRY STREET RUTHERFORD,PA RE: 47659 CHRISTINE PARR Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relaling to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-2934l6 47659-LZ9 " I., , " L.'~:" ", -'U~IllJ:', CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 03/27/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-242369 47659 -L3 0 .- "J,.k ',~" "" -''''''~' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OP IN'rBN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMBN'l'S AND THINGS PORDISCOVERY PURSUANT TO RULE 4009.21 [ Rote: see enclosed list of locations. 1 TO: JAMIE L. SIIELLEIl. ESQUIRE --..c' MCS on behalf of ltEHllETB S. PAll.. ESQUIU 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 fil. 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. thea the subpoena may be served. Complete copies of any reproduced records may be Ol'cIel'N at your expense by completing the attached counsel card and returnina ._ to MCS or by contacting our local MCS office. DATE: 03/06/2001 MCS on behalf of KEHHETII S. FAl". ESQUIRE Attorney for DEPEHDAII'l' CC: KEHHETB S. PAl... ESQUIRE LARRY ROTllWEllll - 03UJ.OO'.. - 1IM04410J-n Any questions regarding this matter. CODtact THE MCS GIlOUP IRC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-146648 47659-C02 RECOllDS REQUESTED MEDICAL , BILLING MEDICAL , BILLING MEDICAL , BILLING OTHER OTHER OTHER MEDICAL AND HOSPITAL BILL MEDICAL , BILLING >>> LOCATION LIST <<< IL .- > , ~;:.. .- linli"'!!'&,; PAGE: 1 LOCATION lfAMB HEALTHSOUTH REHAB DR. WILLIAM BUSH JOD VICKORY. M.D. IIA1lRISBtJB.G PIIAllMACY RID-AID CORPORATION CVS PIIAllMACY OSTEOPATHIC HOSPITAL DR. JOHN GOLDMAN --....."" DE02-146648 47659-C02 ".' ,",. ~ '; ~ "~ ilolia'" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLA_':O PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMTh"TS OR THINGS FOR DISCOVERY PURSUA.l'l;"T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: JOHN VICKORY, M.D. (Na.me of Person or Entity) vVithin twe:'t:). (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: - at MCS GROUP INC., 1601 MARKET ST., #800. PRILA..PA 19103 (Addr...) You may deii\-.. or mail legible copies of the do<:uments 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 h...e the right to seek, in ad,'ance, the "'..onable cost of preparing the copies or producing the things sought. If you fail to T-oduce the documents or things required by this subpoena. within twenty (20) days after its se....';ce, the party sendng this subpoena may seek a court order compelling you to comply with r... nt;S SL"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: !\AME: KlO'l\ThT"""T'U c: lfA TR r . F.SQTTTRF. ADDRESS: l ~45 \{ALNUT ST., 19TH FLOOR PHTTA PA lQ101 TELEPHONE: 215-246-0900 SUPRE!\.{E COURT ID #: AITOR."EY FOR: DEFENDANT DATE: m::J/JrL :J ;:) or", . Prothono~,IOe:rk. v Ivision -40.,.17 _ P _ ~J)Af-m r. ~ ty '- Seal of the Court -=,;.. - '9:1 c'- -,I - I ~'~' I ,. ,.,n ilII;/l!f:;" EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN VICKORY, M.D. NEW CUMBERLAND, PA RE: 47659 CHRISTINE PARR 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: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-Z934l8 47659 - L3 0 .' ~ "~ I.' , I" '.-,","~'-"'~ - '.", '''~'' - "'l:J\i.f., CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 -..~. MCS on behalf of KENNETH S. FAIR, 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: 03/27/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-242370 47659-L31 - . .c. ,I Ik ,-'=~~ - , "~ " Wff',; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF IN'rEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCllMEN'rS AND TllINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations. ] TO: .JAMIE L. SHELLER, ESQUIBE KCS on behalf of KEHNETR S. FAIR, ESQUIllE 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 KCS office. :......: nlTE: 03/06/2001 KCS on behalf of KEHNErB S. FAIR, ESQUIBE Attorney for DEFENDANT CC: KENIlETR S. FAIR, ESQUIBE LARll.Y NOTRWEIIR 03125-00368 - HM044705-SV Any questions regarding this matter. contact THE KCS GROUP DlC. 1601 MAUE'1' STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-146648 47659-C02. I , ~ ,~i,1 ,,: ~ "', ' )i:" ~ ".''- '^1r.1Mu >>> LOCATION LIST <<< PAGE. 1 RECORDS REQUESTED LOCATION !fAME MEDICAL , BILLING MEDICAL , BILLING MEDICAL , BILLING OTBn OTBn OTBn MEDICAL AND HOSPITAL BILL MEDICAL i BILLING BEALTHSOUTB REHAB DR. WILLIAH BUSH JOBlf VIClCORY. H.D. HAlUlISBtmG PBAllMACY RITE-AID CORPORATION cvs PBAllMACy OSTEOPATHIC HOSPITAL DR. JOBNGOLIIMAlI _-.....~ DI02-146648 47659 - C () 2 1.-'" ,. , " ',,;,... " N''''';''''-- h~,', COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL.~"D PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMTh"TS OR THINGS FOR DISCOVERY PURSUA.I\"T TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR:HARRISBURG PHARMACY (Name o( Penon or Entity) \oVithin no."e;r.:.' (20) days after service of this subpoena, you are ordered by th~ court to produce the following documents or things: - . at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You may deiiver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate a! compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the :easonable cost of preparing the copies or producing the things sought. If you fail to ;r.'oduce the documents or things required by this subpoena. ...ithin twenty (20) cays after its service, the party serving this subpoena may seek a court order compelling you to comply Yrith r_ THIS SL'BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: --y"'l\Th11i'T~ ~ 1f'AT~ F~<1nT'RF. ADDRESS: 1845 WALNUT ST., 19TH FLeeR PHTTA l>A lQl0, TElEPHO~E: 215-246-0900 SUPREME COURT 10 It: AITOR.'\EY FOR: DEFENDANT DATE: (tb/JrL ':J ~061 , " - Seal of the Court _" -: 9:-'1 I. ,,_I , .-, 0", ,,'- - i&JDii EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG PHARMACY 2645 NORTH 03RD STREET HARRISBURG, PA 17110 RE: 47659 CHRISTINE PARR COPY OF ANY AND ALL PRESCRIPTIONS. Subject: CHRISTINE PARR -...,: , Social Security #: 175~48-3034 Date of Birth: 11-20.1957 SUlO-293420 47659-L3::L ~ . I . .,--',-", "'," -.:r CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 -..-' MCS on behalf of KENNETH S. FAIR, 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: 03/27/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-242371 47659-L32 , 1,,,- ~'.' "1lilll,,~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF IN'rBN'.r TO SERVE A SUBPOENA TO PRODUCE DOCUMBN'.rS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Rote. see enclosed list of locations. ] TO. JAMIE L. SIIELLE1I.. ESQUIllE -,..,~ MeS on behalf of lCEHllETH S. FAIR, ESQUlllE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlD 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 erpense by completing the attached counsel card and returning same to MeS or by contacting our local MeS office. DATE. 03/06/2001 MeS on behalf of KEHH!TH S. FAIl. ESQUlllE Attorney for DEFEIIDAHT CC. KEHH!TH S. FAIR, ESQ1JIU LARll.Y ROTBWEllll - 03125-00368 - BM044705-SV Any questions regarding this matter, contact TIlE MeS GROUP IRC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l46648 47659-C02 - . RECORDS REQUESTED MEDICAL , BILLING MEDICAL , BILLING MEDICAL , BILLING OTHER OTHER OTHER MEDICAL AND HOSPITAL BILL MEDICAL , BILLING I~ >>> LOCATION LIST <<< ~-~ I _ "'. PAGE. LOCATION NAME BEAL'THSOUTB REHAB DR. WILLIAM BUSH JOHN VICKORY. M.D. HARRISBURG PIIAllKACY RITE-AID CORPORATION CVS PIIAllKACY OSTEOPATHIC HOSPITAL DR. JOHN GOLIlMA1I , , -- 'iflij", 1 -~~;..; DE02-146648 47659 - C () 2 , . ~ "'~~,',...~ .~. "", -~ ,~ '\i"'inK COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL~'iD PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMThlS OR THINGS FOR DISCOVERY PURSUA.!I.;l TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: RITE AID (Name of Person or Entity) \tVithin t"\o\ooe:t:}" (20) days after service of this SllJ,?oe~a. you are ordered by the court to produce the following documents or things: -~ ," MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 IAddrn.) at You may deii...,,. or mail legible copies of the documents or produce things ""!uested by this subpoena. together with the certificate IT. compliance, to the party making this request at the address listed ~bo\'e. You have the right to seek, in ad"once, the ,...onable cost of preparing the copies or producing the things sought. If you fail to ;:oduce the documents or things re,quired by this subpoe~ ""itfoo..in twenty (20) days after its se:"'.':ce, t:-'e ,:la.~. serving this sl:.bpoena may seek a court order comp~nh3' ~.,ryU to c':Imply "",;th r... THiS SLllFOENA WAS ISSUED AT THE REQC.:;.5T OF THE FOLLOWING PERSON: SAME: KF1q1\Jl4''l'~ ~ YAT~ r .,"FSQ1HRF. ADDRESS: 1845 WALNUT ST., 19TH FLOOR ?HTTA ?A lQ101 TELEPHO:\'E: 215-246-0900 SUPREME COURT ID It: AITOR.'\EY FOR: DEFENDANT BY DATE: ~;)cL ::l :l D6/ , prothonotary/Oerk. Civil . . n ~a,." _ P ~q/!AT \..-/- '----- Seal of the Court _ . ~ c;-) '" .1 1,_ "~. I, ,,' - ""-',,. -uil!i<k EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RITE-AID CORPORATION P.O. BOX 3165 HARRISBURG, PA 17105 RE: 47659 CHRISTINE PARR COpy OF ANY AND ALL PRESCRIPTIONS. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date t>fBirth: 11-20-1957 SUlO-293422 47659-L32 ~"hi"""c"~,--,,",,,' .",,~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 03/27/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-242372 47659-L33 '.,1 < ~ " ~" -j -- -,- ,~,- "",' c~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF IN'l'EN'l'. TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: .JAKIE L. SRRT.T.R1I, ESQUIllll: _.. . MCS on behalf of KENIlETB S. FAIR, ESQUIllll: 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 ia 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 completina the attached counsel card and returning same to MCS or by contacting our local KCS office. DATI: 03/06/2001 KCS on behalf of KENIlETB S. FAIR, ESQUID Attorney for DEFEHDAft CC: KENIlETB S. FAIR, ESQUlU LAlUlY HOTBWEIIlt - 03125-00368 - BK044705-SV Any questions regarding this matter, contact THE KCS GROUP INC. 1601 HAllXET STREET #800 PHILADELPHIA, PA 1910' (215) 246-0900 DE02-146648 47659 - C 02 RECORDS REQUESTED MEDICAL " BILLING MEDICAL " BILLING MEDICAL " BILLING OTHER OTHER OTHER MEDICAL AND HOSPITAL BILL MEDICAL " BILLING ~I >>> LOCATION LIST <<< "' , - PAGE: 1 LOCAnON !fAME BEALTlfSOUTH REHAB DR. WILLIAK BUSH JOHN VICIroRY. H.D. HARRISBURG PIIA1lMACY RITE-AID CORPORATIOIf CVS PIIA1lMACY OSTEOPATHIC HOSPITAL DR. JOHN GOLDMAN -~,..; DE02-146648 47659-C02. - "I ,J .C ". ;,". ~11' L.,~! COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLA..'W PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMTh-rS OR THINGS FOR DISCOVERY PURSUA.l\;-r TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CVS (Name of Person or Entity) \\'ithin rwe~' (20) days after service of this subpoena, you are ordered by the CDurt to produce the following documents or things: -"" at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 IAddrHs) You may deih'er or mail legible copies of.the documents or produce things requested by this subpoena. together with the certificate 0; compliance. to the party making this request at the address listed above. You have the right to seek. in advance. the ,....onable cost of preparing the copies or producing the things sought. If you fail to ?"oduce the documents or things required by this subpoena. ,,;!:'.in twenty (20) cays after its sen'ice. the party serving this subpoena may seek a court order compelling you to comply ,,;th r_ THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: J::E~Thl'F""~ ~ 'FA,T'R 'F~QTTTRF. ADDRESS: 1845 WALNUT ST., 19TH FLOOR PJ:rTT A .PA l'll03 TELEPHOSE: 215-246-0900 SUPREME COURT ID #: AITOR.'\'EY FOR: DEFENDANT DATE: fYl;, 1'1..1:..1,__ ~ -::J. r')Q/ I . '-- Seal of the Court '-~~'f ;' -'97) -,-I L.,. " ,'i b'"',,- ",',-", '~'"'Y"'_ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CVSPHARMACY ONE CVS DRIVE WOONSOCKET, RI 02895 RE: 47659 CHRISTINE PARR COPY OF ANY AND ALL PRESCRIPTIONS. (STORE LACATED IN THE WINDOSR PARK SHOPPING CENTER, MECHANICSBURG PA) Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SUlO-293820 47659 -L3 3 .,", ." - ,,~ ' lit-- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a pre~equisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 03/27/2001 KENNETH S. FAIR. ESQUIRE Attorney for DEFENDANT DEll-24237347659-L34 1- I' I L ~. """,-".,...' - W41~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN TH~ MATTER OF, COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: JAMIE L. SHELLER, ESQUIRE KCS on behalf of KENNETH S. FAIR, 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 recorda 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: 03/06/2001 MCS on behalf of KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT CC: KENNETH S. FAIR, ESQUIRE LARRY NOTHWEHR - 03125-00368 - 1IM044705-SV Any questions regarding this matter, contact THE MCSGROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l46648 47659-C02 ,- . ~. RECORDS REQUESTED MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING OTHER OTHER OTHER MEDICAL AND HOSPITAL BILL MEDICAL & BILLING _I . >>> LOCATION LIST <<< - "J PAGE: LOCATION NAME HEALTHSOUTH REHAB DR. WILLIAM BUSH JOHN VICKORY, M.D. HARRISBURG PHABMACY RITE-AID CORPORATION CVS PIIA1lMACY OSTEOPATHIC HOSPITAL DR. JOHN GOLDMAN "'~:'"' ._-:;;~~,_: 1 DE02-146648 47659-CO:2. ~~ ~-I , I, ' '~'"', -'" -,~ - ~!;;':t'", COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICB OF IlI'rBN'l' TO SBRVE A SUBPOENA TO PRODUCB DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: JAMIE L. SBELLEK. ESQUIRE KeS on behalf of KENNETH S. FAIR, 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 ezpense by completing the attached counsel card and retuming s_ to KeS or by contacting our local KeS office. -.....; -....' DATE: 03/06/2001 KeS on behalf of KENNETH S. FAIR, ESQUIRE Attomey for DEFENDANT CC: KENNETH S. FAIR, ESQUIRE LAlUl.Y NO'lllWEllll - 03125-00368 - BH04470S-SV Any questions regarding this matter, contact THE KeS GROUP INC. 1601 MARKB'l STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l46648 47659 - C () 2 RECORDS. REQUESTED MEDICAL (, BILLING MEDICAL (, BILLING MEDICAL (, BILLING OTHER OTHER OTHER MEDICAL AND HOSPITAL BILL MEDICAL (, BILLING " >>> LOCATION LIST <<< , ,.~- I "" PAGE: LOCATION NAME IlEALTHSOUTH REHAB DR. WILLIAM BUSH JOHN VICKORY. H.D. HARRISBURG PHAllHACY RITE-AID CORPORATION CVS PHAllHACY OSTEOPATHIC HOSPITAL DR. JOHN GOLDMAR ~"....~.,J,.~~ "".'"'~'" 1 .:,::;:j-": DE02-l46648 47659-C02 1"- . , ~' c_ 'L =itm~,_ COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLA_'..:D PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMTh'TS OR THINGS FOR DISCOVERY PURSUA.1'I,;'T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: THE OSTEOPATHIC HOSPITAL (Nam~ of P~non or Entity) V\oithin n--O!:t:)o (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: -. c MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 IAddrns) al You may dellio.. 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 ",..onable cost of preparing the copies or producing the things sought. If you fail to ;r.-oducethe documents or things required by this subpoena. "';thin twenty (20) cia,'s after its service. the party sen-oing this subpoena may seek a court order compelling you to comply with r... THIS SL"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: !\ AME: Kit-ThTlf"T'l=f c:: 1? A TR 'F.S01TTRF: ADDRESS: 1845 WALNUT ST., 19TH FLOOR PltTTA PA lQ101 TELEPHONE: 215-246-0900 SUPREME C01JRT ID It: ATIOR.'\EY FOR: DEFENDANT DATE: fYl ::J (} r'1. :J ~OO I . /--- ---- Seal of the Court (Efr. i /97) , ';",~" "j"- '" ,,,,-~ "'-" ,--., EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: OSTEOPATHIC HOSPITAL 4300 LONDONDERRY RD. PO BOX3000 HARRISBURG, PA 17105 RE: 47659 CHRISTINE PARR Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultalion, care or treatment of patient. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20.1957 SUlO-293426 47659-L34 1_, I , :,1 " ~ '<'~,~ ~,'" CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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 ha. been received, and (4) The subpoena which will be served 1. identical to the subpoena which is attached to the notice of intent to serve the subpoena. HCS on behalf of DATE: 03/27/2001 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-242374 47659-L35 " -.' . -1- .. ;'. .~ I.. , , ~ ~~. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PARR TERM, -VS~ CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NO'l'ICE OF IR'RR'l' TO SERVE A SUBPOENA TO PRODUCE DOCUHER'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note. see enclosed list of locations ] TO. JAHIE L. SHELLn, ESQUIU HCS on behalf of KENNBTIl S. PAIR. ESQUIU 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. -~..: nATE: 03/06/2001 HCS on behalf of KENltETH S. FAIR. ESQUIRE Attorney for DEPEBDAtrr CC. KENNETH S. PAIll, ESQUIU LAIlIlY NO'!BVBII1l - 03125-00368 - BM04470S-SV Any questions regarding this matter. contact THE MCS GROUP DlC. 1601 MARD'l STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-146648 47659-C02 ~~ ,'~" RECORDS REQUESTED MEDICAL I. BILLING MEDICAL I. BILLING MEDICAL I. BILLING OTHER OTHER OTHER MEDICAL AIm HOSPITAL BILL MEDICAL I. BILLING ., >>> LOCATION LIST <<< 'J.; PAGE: LOCATION IfAMII: HEALTHSOlJ'l'll REIIAa DR. WILLIAM BUSH JOHN VICIDRY; M.D. HARRISBURG PIIAllMACY RITE-AID CORPORATION CVS PIIAllMACY OSTEOPATHIC HOSPITAL DR. JOHll GOLDMAlf ~ . I .ladjlfu."1 I I 1 --,,""'::....- DEOZ-146648 47659-C02 vi - ~'~+~ COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERL-\...-..;'D PARR VS File No. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUMTh'TS OR THINGS FOR DISCOVERY PURSUA..1'I,;'T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. JOHN GOLDMAN (N.ame of Penon or Entity) \i\.~ithin twe~' (20) days after service of this subpoena, you are ordered by the court to produce the foBowing documents or ~~g~ -" MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) at You may dem'.. 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 ha,.e the right to seek, in ad"an,". the ,...onable cost of preparing the copies or producing the things sought. If you fail to ;r.oduce the documents or things required by this subpoena. within twenty PO) da~'s after its service, the party sen'ing this subpoena may seek a court order compelling you to comply with r_ THIS SliBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: VllJ>Th1"'1'1'l <\ "nll 1'.~Q1Jill1'. ADDRESS: 1845 WALNUT ST.. 19TH FLOOR P1'lTT,A PA 1<l103 TELEPHO:\E: 215-246-0900 SUPREME COURT ID #: ATIOR.~EY FOR: DEFENDANT DATE: (y?;;;/j ~1. :J JJ'~ I . ---- Seal of the Court (Ef!. i /97) ',I , ~ --~ - "', ,- > "jlJ>-' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JOHN GOLDMAN HARRISBURG, PA 17109 RE: 47659 CHRISTINE PARR 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: CHRISTINE PARR , Social Security #: 175.48-3034 Date of Birth: 11-20-1957 SUlO-293428 47659-L35 rm "~;"~ ,--~.' "," , "" ~ _~w __,' ~"' '-.rill ~.;r.m.~;i;!~~ll,g:iii!li~ "" ", ',""",,,' ,,~-~,-- > ,'",",'" ','I :li!I!.ll ~ Jiii ]81.1 i.-llIiflJ' ,~. " '. r-- - (") c: <~ -orf in!")'": Z:'-J: 2~ ~'_;~ (fJ,~ " -<~. ~:::C) d:';(; );: ~,~ Z :~ o o -n """ -0 ;::0 , w -0 ~ :D ('-- CC1 CJ , ,! , ':i ~~:~ (,....,--'-' ~:.:~~ C -~, ..:-:.:",'\:\ C) -,,-1 '"1:> ~:J -< i;? N " ' ,~ ,-- _-.l,,~ >1" ;1_ ,--' ""''liI." CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.ZZ IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KENNETH S. FAIR, 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: 01/15/2002 MC~ on 1'lhl'lf ~f _ . ~\<:"~'1!U}..= KENNETH S. FAIR, ES UlRE Attorney for DEFENDANT DEll-304582 47659-L36 ,~~" ... I ',~ j,. ,~ 1 . - " ~-- ~, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTEH'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEH'l'S AND THINGS FOR DISCOVERY PURSUAH'l' TO RULE 4009.21 MARTIN FLANNERY MAlUt GRUBB BEALTHSOUTH REHAB OTHEll. MEDICAL MEDICAL RECORDS & DAYS TO: JAMIE L. SHELLER, ESQUIRE K'iS-. on behalf of KENNETH S. FAIR, 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 KCS office. DATE: 12/26/2001 KCS on behalf of KEIIlIETH S. FAIR, ESQUIRE Attorney for DEFENDAN'I' CC: KENNETH S. FAIR, ESQUIU LARRY NOTllWEllll - 03125-00368 - BK044705-SV Any questions regarding this matter, contact THE HCS G~ INC. 1601 KARlET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l73992 47659-C02 '" '" ~ ~.~ I~ ~_ J_ I , _ ~" '" 'j-' . "" ,..,~ , "~-~,.;.ifu: COMMONWEALTH OF PENNSYLVANIA , COUNTY OF CUMBERL-\..'iD CHRISTINE PARR vs File :'\0. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUME-.,.S OR THI~GS FOR DISCOVERY PURSUA.l\,. TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB HOSP. (S.m. of p~"o" or Clary) V,'i:hin twe",,' 1::0) dol" oil.. .ervice of thi. subpoe~ you ue ordered by the C'llUrt to produce the fallowing documents or 'hj"SS' SEE ATTACHED . it MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (.~d_'1 You mol' deu-'ft or mail legible copies of the documents or produce thinp req"ested by this .ubpoen..together with the certificote ai romplimce. to th. puty mU.ing this request orth. oddn!Ss Usrecl..bov.. You ho\'llhe right 10 ...k. in .dunce. ~... ,..so....bl. cost of prepmnsth. copies or producinglhelhinp _gl\l. If ~'au fail to ;::aduce the docum.nts or things required by this subpoen.a. wit.':in lW.nry (::01 d..~.s oiler its ",,'i<o. the pury ""'ing this slJbpo.no mol' seek 0 court order comp.llinS you to comply with it.. THIS St"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: :'\....\{E: ....DDRESS: KENNETH S. FAIR , ESQ. 1845 WALNUT ST., 19TH FLOOR PHILA,PA 19103 215-246-0900 TEI.EPHOS:: StlPRE.'fE COU'RT ID t: .....rrOR.'OEY FOIt: nF.'FRNOAN'r BY , DATE: J)CC"' II. ;)..CX) I . --- Seal of the Court (:.fl. i /97) 'I <<<, 1'- vi; , ->" ;-.:,i '.__.n.. ,,""', ,~:,;. EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MARTIN FLANNERY 98 S. ENOIA DRIVE SUITE 204 ENOIA, PA 17025 RE: 47659 CHRISTINE PARR ANY AND ALL TAX RECORDS Suhjed : CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 SU10-346160 4765 9 -L3 6 d'"';';;' ,- " ~ ~, - '"I ,~,",- ,;;-, '^ h,'ilil't, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC.. ET AL As a prerequisite to service of a subpoena,for documents and things pursuant to Rule 4009.22 -~ MCS on behalf of KENNETH S. FAIR, 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: 01/15/2002 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-304583 4765 9 -L3 7 - .1 I "- 1--, ^~ ,;;, '~._",,', ~L, . i'a1k COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 KARTIlI FLAlIBE1lY HARK GRUBB HEALTHSOUTH REHAB OTllEll MEDICAL MEDICAL RECORDS , XRAYS TO;...JAKIE L. SIIELLE1l, ESQtJlRE KeS-on behalf of KENtlETH S. FAIR, ESQtJlRE 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 Jour erpense by completing the attached counsel card and returning same to KeS or by contacting our local KCS office. DATE: 12/26/2001 KeS on behalf of KEHRETH S. FAIR, ESQtJlRE Attorney for DEFEHDART CC: KEHRETH S. FAIR, ESQtJlllE LARRY ROTtl_ - 03125-00368 - BM044705-SV Any questions regarding this matter, contact THE KeS Gaelii> IRC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-173992 47659-C02 0'_ I -J,,,_ --, ." i'M:~,ii: COMMONWEALTH OF PENNSYLVANIA , COUNTY OF CUMBERL.-\..'iD CHRISTINE PARR VS File So. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DOCUME-.,.S OR THI~GS FOR DISCOVERY PURSUA."" TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: MARK GRUBB (Sun. of PInon or !:ldry) Within rwe",,'I::O) dol" oiler service of this subpoe..... you .... orderecl by the (gun 10 produc. th. following docum.nt. or things: SEE ATTACHED . , ,t MCS GROUP INC., 1601 MARKET ST., #800. PHILA.,PA 19103 I.~d_'l You mol' d.ih,ft or mail legible copies of th. documents or produce thinp reqaested by this subpoenL tog.ther with th. rtrtificOIO ai rOlllpliUlc..lO th. puty llIwnglllis r"luesl .llh. Iddn!Ss Usrecl above. 'You hove the righl to s..k. in .d\'Once. th. :tuo....bl. cost of pr.pmnsthe copies or producinllhelhinp _gill. If you fail to ;::aduc. the docu.m.nts or things requir.d by this subpoen.a. wit."Jn lW.nry (::0) c..y. oiler its .e,,'irt, the pury .."'ing this slJbpo.no m..y seek I court order comp.lling you to comply with it.. THIS StllPOENA WAS ISSUED AT THE REQUEST Of THE FOLLOWING PERSON: KENNETH S. FAIR , ESQ. 1845 WALNUT ST.. 19TH FLOOR PHILA,PA 19103 TELEPHOS:: 215-246-0900 StlPRE.\{E COIJ1lT ID I: :\ rroR. 'On FOR: :\AME: ...DDRESS: n'Rli'li'1\mAl\T'T' DATE: ~;:r II ;:).06 f . ilian <....... Seal of the Court (Eff. i /<J7) - .1- EXPlANATION OF REQUI TO: CUSTODIAN OF RECORDS FOR: MARK GRUBB HARRISBURG, RE: 47659 CHRISTINE PARR '_'_"" I D RECORDS Any and all records, correspondence, files and memorandu s, handwritten notes, billing and payment records, relating to any examina ion, con~ul1ation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175-48-3034 Date of Birth: 11-20-1957 ,J,^ '. ~- ):r~~ SUlO-34616Z 476S9-L37 ,.,1_.... ,~, 'Y .~, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 - ~ MCS on behalf of KENNETH S. FAIR, 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: 01/15/2002 KENNETH S. FAIR, ESQUIRE Attorney for DEFENDANT DEll-304584 47659 -L38 [''''''1;''- ,," ,I ~ ,';,---,,;-r _ ^~" _ '" " '-'-"n-1t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTINE PARR TERM, -VS- CASE NO: 00-06887 KEYSTONE SPINE CENTER, INC., ET AL NOTICE OF INTEN'r TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'rS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MARTIN FLANJlERY MARK GRUBB HEALTHSOUTH REHAB OTHER MEDICAL MEDICAL RECORDS Ii XRAYS TQ.; ...JAMIEL, SHELLER, ESQUIRE KCS on behalf of KENNETH S. FAIR, 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 KCS office. DATE: 12/26/2001 KCS on behalf of KENNETH S. FAIR, ESQUIllE Attorney for DEFENDANT CC: KENNETH S. FAIR, ESQUIRE LARRY NOTIIVEBR - 03125-00368 - HH044705-SV Any questions regarding this matter, contact THE KCS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-173992 476S9-C02, ="""'~" ~" . '; .' "~, """"'!lfi' COMMONWEALTH OF PENNSYLVANIA ' COUNTY OFCUMBERL-\..'iD CHRISTINE PARR VS File :'\0. 00-06887 KEYSTONE SPINE CENTER, INC., ET AL SUBPOENA TO PRODUCE DO~,.S OR THI~Gs FOR DISCOVERY PURSUA.l\,. TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: MARTIN FLANNERY (S.,..1t of P~on or =al!) \','hhin rwe",,' 1::O} dol'S oil.. .ervic. of this subpoe..... you ue ordered by the _to produc. the folIowinl docum.nts or th~np; ~1<'1<' A'T''T'Ar.HRn . 01 MCS GROUP INC.. 1601 MARKET ST.. 1/800, PHILA.,PA 19103 (Addtos.. You mol' d.u-.ft or maillegibl. copies of the documents or produce thinp req"est.d by this subpoen.. together with tho rertifiut. ai romplimce. to th. puty mwnlthis request otthe oddn!Ss Usrecl.abov.. You ho... th. right to seek. in .dunc..the :fuonobl. cost of prepuinlth. copies or producinl the lhinp -shL If you fail to ;::oduce the docu.m.nts or things required by this subpoen.a. wiu-.ift lW.nry (::0) d..~.s oiler it. se,,';ce, the pury ser\'inglhis slJbpoe.... m..y seek I court order comp.llinl you 10 comply with it.. nus St"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: :'\AME: KENNETH S.FAIR. ESO. AODRESS: 1845 WALNUT ST.. 19TH FL PHILA. ,PA 19103 215-246-0900 TELEPHOS:: St.!PRE.\{E COURT 10 t: A1iOR.'O['{ FOR: nR'FRNnAN'T' DATE: ~t;.r 17 .;21')D J , - ~ B~-%~~ 1'rIItIum-.ylOeIc,. Dlvi.ion ~/J.-.. '" _ P 22Cf'?/U'T" r Oepu. "-- Seal of the Court (Sf!. i /97) ""I~ ~ ...-", '1--' " ., .~~< -- --',;--', ~' EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB 920 CENTURY DRIVE MECHANICSBURG, PA 17055 RE: 47659 CHRISTINE PARR UPDATED RECORDS INCLUDING DISCOGRAM DONE SEPT, OCT, & NOV 2001 Any and all records, correspondence, files and memorandums, handwritten noteJ'".original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CHRISTINE PARR , Social Security #: 175.48.3034 Date of Birth: 11-20-1957 - SUI0-346164 47659-L38 .~';'~="'~~oit<i!6i,Ji~ti~~~;\jj~~:lii,;$&Id!j;d;!lJ,,",~~ii,"j<;j!j\:i"""~'~'^"'a'_~11 "," u.. ,~. "' J~_ ~,"~ <, ~,- -,-"~ ~, - "~ "~ llli ,.,.. ihltl..l:J i"""'"......~. .. ~., .~- """'~ ,0., 0 "0 'c t'0 -1"1 s: '- "'O:{";O ~ F{~'. ~cq z Z~O ,'~ w5;;; m X, ?;"'-. ~<:> "",0 -0- -r- "'1"" ~O ~ --p:;:-d - --:-/5 :1>2 ~ OJ:SM z 0 ?i5 ~ 0 -< " ,"--'~ .. I' W. -;.-'" """=_,0'___ SHELLER, LUDWIG & BADEY By: Jamie L, Sheller, Esquire Identification No, 55722 1528 Walnut Street - Third Floor Philadelphia, PA 19102 215-790-7300 , " "I' ,"' ',w ,." " ~ - '_ >l_' - - = ,c";",-e,___"," ;' '1.' I I , I Attorney for Plaintiff CHRISTINE PARR vs, KEYSTONE SPINE CENTER, INC, and RUSSELL F, POOLE, P,T, COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL TERM NO, 00-6887 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter as Discontinued and Ended, Dated: 9/14/2004 SHELLER, LUDWI EY L. SHELLER, ESQ LAW OFFICES SHELLER, LUDWIG & BADEY I' . "'I ... ~_,o_ ,'.1,;-"_,,_,, ,~' '. "'" ," ----:) SHELLER, LUDWIG & BADEY By: Jamie L. Sheller, Esquire Identification No. 55722 1528 Walnut Street - Third Floor Philadelphia, PA 19102 215-790-7300 Attorney for Plaintiff CHRISTINE PARR COURT OF COMMON PLEAS CUMBERLAND COUNTY vs, KEYSTONE SPINE CENTER, INC, and RUSSELL F, POOLE, P.T. CIVIL TERM NO, 00-6887 CERTIFICATE OF SERVICE I, Jamie L. Sheller, Esquire, attorney for Plaintiff, Christine Parr, hereby certifY that I served a true and correct copy of the Praecipe to Discontinue and End by regular first-class mail on the following: Kenneth S, Fair, Esquire John C, Farrell, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 1845 Walnut Street Philadelphia, PA 19103 Date: 9/14/2004 LAW OFFICES SHELLER, LUDWIG & BADEY I" I I i iliI ~,<:l:tL~!j~M!!ffii~\!jl~"-' '. >H ~ ,W;iJj~l'~~t~L~rj .=. :M';~","",,"'" .1 ~ e. . ~iiii:i1l '..0'';';''; ~ ~ C) r ~~~~ -C':;-'D:: ,..."! 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