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HomeMy WebLinkAbout00-08571 -~- '" L . , ,(, =~"Iililmd MORGAN & MORGAN, P.C. BY: SCOTTW. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF CAROL HAMMOND 2310 Enola Road Carlisle, PA 17013, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00 - J>S'''lj C;(J~C-T~ v. CIVIL ACTION - LAW CHARLES A. HOCKENBERRY, II R.D. 1, Box 101 Blain, P A 17006, JURY TRIAL DEMANDED Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ~ L , ,;' I ~__ '-~'."~,,, A VISa Le han demandado a usted en la corte. Si usted defenderse de estas demandas expuestas en law paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas dernandas en contra de su persona. Sea avisado que si usted no se defiende, ia corte tomara medidas y puede continuer ia demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decodor a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO a SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 .~ ' j r,~.. MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF CAROL HAMMOND 2310 Enola Road Carlisle, PA 17013, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. ~. 8'S7/ CU;J I~ v. CIVIL ACTION - LAW CHARLES A. HOCKENBERRY, II R.D. 1, Box 101 Blain, PA 17006, JURY TRIAL DEMANDED Defendant COMPLAINT Plaintiff, by and through her attorneys, Morgan & Morgan, P.C., hereby complains against Defendant and avers as follows: 1. Plaintiff is an adult individual residing at the above address. 2. Defendant is an adult individual residing at the above address. 3. On or about March 14, 1999, Plaintiff was operating her motor vehicle on Longs Gap Road near North Middleton Road in Carlisle, PA, when Defendant, who was operating a motor vehicle on North Middleton Road, caused a collision with her vehicle. 4. As a result of the collision, Plaintiff suffered severe, serious and disabling injuries, including but not limited to, injuries to her nerves, bones, muscles, joints and fascia, pain and suffering, mental and emotional distress, which are continuing in nature. '" _. .dL " J _._-,~""""~ 5. As a result of her injuries, Plaintiff incurred medical bills for care, treatment and rehabilitation, has suffered loss of earnings and/or earning capacity and suffered diminution of daily activities and loss of life's pleasures, which are continuing in nature. 6. It is averred that Plaintiff suffered serious injuries as said injuries are defined under the Motor Vehicle Financial Responsibility Law. 7. Plaintiff's injuries and damages were due to the negligence of Defendant, including: A. Traveling at an unsafe speed; B. Failing to stop at a stop sign; C. Failing to yield the right of way to Plaintiff; D. Failing to keep a proper lookout; E. Failing to keep his vehicle under proper and adequate control; F. Failing to warn Plaintiff of an unreasonable risk of harm; G. Striking Plaintiff's vehicle; H. Failing to stop at a controlled intersection; I. Proceeding in the face of oncoming traffic; J. Violating state laws and local ordinances relative to the above allegations of negligence. 8. As a further result of Defendant's negligence, Plaintiff suffered damage to and loss of use of her motor vehicle; J I'. .II_"'ill~""lJll1iIM;;r.' WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $35,000.00, exclusive of interest, costs and delay damages. MORGAN & MORGAN, P.C. Q.:;e- c l \ DATED: ~--;',,"iber _, 2000 "k; ,'" ~ " '.' , -"'......"""'~"~., VERIFICATION Carol Hammond states that she is Plaintiff in this matter, and that the statements made in the foregoing Complaint are true and correct to the best of her knowledge, information and belief She understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. C&)~ Carol Hammond .\ "," illIi" ", ""'~"'''__ffi,,,,_,"~,,,",,,".~A'~J''d'''''''''''''''''.',,~,,,,,,,'""'--""'-"'''_&,,,"'-_1.... '. '~"~ ," ' ,I (") 0 C) ~- 0 '., c... S. ;:::J -oel rq ,1 '(q r11fT\ ("') r':=--'; t:> (:) Z:~n ~r;nl <- ~ :zr~ "I? t U<::C,: N 2(,) 8 fI:. cS _...L._~ h vt K() -0 '--r---n ,-~:D ~ ~c; :x ",.0 ~ . Z .c, ()in ...... () ~ j>e, ~ c:: ~ C\ 6' z CI7 e () :< ..J -< I I ~ ~ ~ j -, "~ .........." ~ - - ~, ~' ~ ~~ i._ "" ~,""',;dn,IU", 4- SHERIFF'S RETURN - OUT OF COUNTY , CASE NO: 2000-0S571 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HAMMOND CAROL VS HOCKENBERRY CHARLES A II R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: HOCKENBERRY CHARLES A II but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 5th , 2001 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep. York County IS.OO 9.00 10.00 100.00 .00 137.00 .01/05/2001 MORGAN & MORGAN So an~~ ~- .- R. Thomas Kline Sheriff of cumberland County Sworn and ~ <v /0 ~ subscribed to before day Of~ me this ~/ A.D. 0'f'L-Q Yl.1,io(o> ~ Prothonotary "loilWl- ~ ---. ~- -". ~, t' , ' , ....,~j;'''j",,>i "" Carol Hammond IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANI PERRY COUNTY BRANC Versus Charles Hockenberry No. 00-8571 SHERIFF'S RETURN And now January 2 ,2001: Served the within name Charles Hockenberry , the defendant(s) named herin, personally at himplace of residence in Jackson Twp. Perry County, PA, 01'1 January 2 ,2000 at 5:45 o'clock PM by handing to Charles Hockenberry ,an adult member of famil 1 true and attested copy(ies) of the within Complaint & Notice and made known to him the contents thereof Sworn and subscribed to before me this ?/j) , fhll So answers DEPliTY PROTHONOTARY ~ ClERK OF COURTS BlOOMFIELD 80RD.. PERRY co.. PA MY COMMISSION EXPIRES JAN .5, 2004 Jefferson J.Shipman, Esquire I.D. #: 51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant. ,;.'1 .='. ,"~' , ~ '.'.', ',','c.",''''" ',;' CAROL HAMMOND, Plaintiff vs. CHARLES A. HOCKENBERRY, II, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-8571 Civil Term JURY TRIAL DEMANDED PRAECIPE PLEASE ENTER the appearance of the undersigned on behalf of the Defendant, Charles A. Hockenberry, II, in the above- captioned matter. DATE: \ 110 \ a \ 57290.1 GOL BERG, KATZMAN & SHIPMAN, P.C. Je fe on J. Shipman 32 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant ^ ^,^ ^ -"1_, '."'.' ~.^~';-- .'."^""" ~" ~" '::'j, ",',/.. ^,.' 0'~""'" ~',_ - CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on January 5, 2001: Scott W. Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 Attorneys for Plaintiff GOLDBERG, KATZMAN & SHIPMAN, P.C. .'// son J. Sh pman, 3 0 Market Street Harrisburg, PA 17108 Telephone: (717) 234-4161 Identification No.: 51785 Attorneys for Defendant 57291.1 "'" .~'." ,"'--~. ,'.""."'c--,_,-,,,,,""." ',,"," ,'~ '.",'e,".~',''''''"' ,. , ';,'.','''-8'~' ":'''>h'm"i'''' ~"' "'l.iJ~i' Jefferson J.Shipman, Esquire I.D. #: 51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant. CAROL HAMMOND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00-8571 civil Term CHARLES A. HOCKENBERRY, II, Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiff and her Attorney, Scott W. Morgan, Esquire Morgan and Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 YOU ARE HEREBY notified to plead to the within New Matter of Defendant, Charles A. Hockenberry, II, within twenty (20) days of service hereof. GOLDBERG, KATZMAN & SHIPMAN, P.C. erson J. Shi an, ttorney I.D. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant DATE: / /1-y( ~ 57296.1 __'-"" "" ,'",'v" '"8,'C ;" ""'__,_<,C '," c:/ ",,,,,,,,,,,,,,'<,,'~"__'-e_ __, ",'~"''';' ~~ ./' -"',": Jefferson J.Shiprnan, Esquire 1.D. #: 51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant. CAROL HAMMOND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00-8571 Civil Term CHARLES A. HOCKENBERRY, II, Defendant JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, CHARLES A. HOCKENBERRY, II AND NOW, comes the Defendant, Charles A. Hockenberry, II, by and through his counsel, Goldberg, Katzman & Shipman, P.C., and files the following Answer and New Matter in response to Plaintiff's Complaint: 1. Admitted. 2. Admitted. 3. Admitted in part, denied in part. It is admitted only that the Plaintiff was operating a vehicle on Longs Gap Road and Defendant was operating a vehicle on North Middleton Road in Carlisle, PA, on March 14, 1999. After reasonable investigation, , '''''" .~,"" ,~~"~",< '," ~'.>> ",~~', . ~""~o.;,"","" , ~' th: the Defendant is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph No. 3 and the same are, therefore, denied. 4. Denied. After reasonable investigation, the Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph No.4 and the same are, therefore, denied. 5. Denied. After reasonable investigation, the Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph No. 5 and the same are, therefore, denied. 6. Denied. After reasonable investigation, the Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph No. 6 and the same are, therefore, denied. 7. Denied. The averments contained in Paragraph No.7 Subparagraphs A through J are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. By way of further response, it is specifically denied 2 ~__~~' ...,< ____~ ",-". ,~__,_ 'ON "~ _"~__,_ - , ~ ~, ," """'-'; that the Defendant was negligent in any manner with respect to Plaintiff's alleged cause of action. A. Denied. It is specifically denied that the Defendant was traveling at an unsafe speed; B. Denied. It is specifically denied that the Defendant failed to stop at a stop sign; C. Denied. It is specifically denied that the Defendant failed to yield the right-of-way to the Plaintiff; D. Denied. It is specifically denied that the Defend~nt failed to keep a proper lookout; E. Denied. It is specifically denied that the Defendant failed to keep his vehicle under proper and adequate control; F. Denied. It is specifically denied that the Defendant failed to warn Plaintiff of an unreasonable risk of harm; G. Denied. It is specifically denied that the Defendant struck the Plaintiff's vehicle; H. Denied. It is specifically denied that the Defendant failed to stop at a controlled intersection; I. Denied. It is specifically denied that the Defendant proceeded in the face of oncoming traffic; and 3 <'I u~ .' ^^"",. '"-..< ';"'__'. " ,,,,~--,,<,,,, "',. "".. ,.,"'' ,<&"_,',N'",w';'."'" J. Denied. It is specifically denied that the Defendant violated any laws. 8. Denied. After reasonable investigation, the Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments of Paragraph No. 8 and the same are, therefore, denied. WHEREFORE, the Defendant, Charles A. Heckenberry, II, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER By way of further answer and reply, Defendant interposes the following New Matter defenses: 9. That Plaintiff's claims are barred and/or limited by the Pennsylvania Comparative Negligence Statute, 42 Pa. C.S.A. 57102, et seq., and by the Doctrine of Comparative Negligence. 10. That the Plaintiff failed to exercise reasonable care for her own safety under the circumstances then and there existing. 4 "" '" -CO,^,_ 'N" ",.~,' _ '~'. __<""__"."~~__' "'.'~' ~"O'~, ...",~"..,. "'", ",', c' ~~~ 11. That the Plaintiff was comparatively negligent and failed to exercise reasonable care for her own safety, which comparative negligence included, without limitation, the following: (a) Failing to maintain control of her vehicle; (b) Failing to drive her vehicle at a safe speed; (c) Operated her vehicle without due regard for the rights, safety and position of other vehicles on the roadway; (d) Failing to maintain a proper lookout for other vehicles on the roadway; (el Traveling too fast for conditions then and there existing; and (f) Being inattentive to the conditions then and there existing. 12. That the Plaintiff's failure to exercise reasonable care for her own safety was a substantial factor in the happening of the accident. 13. That the Plaintiff's injuries and damages, if any, were not caused by any act, omission or breach of duty by answering Defendant. 5 "-. "~'.Lli 0', "',' " ' "-~,~' <, ',,, ,~' ,"-->'-' '--0, ", ~"'" "," ~'>", ~-h">. ,; ''''~''~,);'''1,''o 14. That the Plaintiff knowingly and voluntarily assumed the risk of her injuries under the circumstances then and there existing. 15. That any damages the Plaintiff may be entitled to recover in this action are limited to those damages which are recoverable under the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. ~1701, et seq. 16. That Plaintiff's claims may be limited or barred by the "Limited Tort" option pursuant to 75 Pa. C.S.A. S1705, et seq. 17. That the accident and any injuries allegedly sustained by Plaintiff may have been caused in whole or in part by the negligence of third persons not presently involved in this action. 18. That if it should be found that there was any negligence on the part of the answering Defendant, which negligence is expressly denied, any such negligence was not a proximate cause of any damages to the Plaintiff. 19. That the Plaintiff's action may be barred by the applicable statute of Limitations. 20. That the Plaintiff's injuries may have been caused by an intervening superseding cause. 6 , . ~ !", ~ ,>" ~ ' ." , '='-'<' "'--~',~ ",," '. c- ~'n.,," 'j~-",,"~" "+" ..", ," "".""J 21. That the action may be barred by the sudden emergency or unavoidable accident theories. WHEREFORE, the Defendant, Charles A. Hockenberry, II, respectfully requests that judgment be entered in his favor and the plaintiff's Complaint be dismissed with prejudice. GOLDBERG, KATZMAN & SHIPMAN, P.C. e erson J. S ipman, ttorney I.D. #51785 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant ~7a2;~ \ /;o/tl7 7 ~ " ~.,~ , <, >.'~' --~,,"', -~-- , ,. >< ~, ". '-.~ -= -~"""A'-_",,,,o~_',_~;<_ ,~. "--J"; VERIFICATION I, Charles A. Hockenberry, II, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing document and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ;jP~/ LA Charles A. Hockenberr ::zz:: II _.'.'" 'v " " '="~-,h ,'."'_. if .",~"" ,,". r- .-+ -0.' "."'~'.- " .. ,) '-'" '-- ''''--.'~ ';';~ "h' " " ;j~~-;.1 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on January 5, 2001: Scott W. Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 Attorneys for Plaintiff GOLDBERG, KATZMAN & SHIPMAN, P.C. erson J. Shipman, Esquire 320 Market Street Harrisburg, PA 17108 Telephone: (717) 234-4161 Identification No.: 51785 Attorneys for Defendant 57445.1 ~_I ,'. -~...lO~MilliI-- = ~.~~ - _c_ ~,~ ,"" ',< -~~ ' ,~,,~ ,~- ~ '. 0 0 0 C " S~ u C'-) :,:1'11 :;-1 rn r"-J ..;Z:; "'T1 6; ::u ,- r- c": r-' N iT1 U) ,h~ "'- ct:<::J -<..:- ::~~=:~ ~..:CJ "U ~~8 :-~ f )__ =~C) Pr" W CSm ~- -/ j;! ,~ =< ::0 -< ',",- - ,". .~ '.I ~'" , '.' '~""lr."~-~<f . - . MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFF CAROL HAMMOND Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 00-8571 Civil Term CHARLES A. HOCKENBERRY, II Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER Plaintiff, through her attorneys Morgan & Morgan, P.C., hereby responds to New Matter of Defendant, and avers as follows: 9-21. The al1egations of these paragraphs are denied as conclusions oflaw to which no answer is required; however, without waiver of same, Plaintiff denies that she failed to maintain control of her vehicle, failed to drive at a safe speed; operated her vehicle without due regard to the rights, safety and position of other vehicles; failed to maintain a proper lookout; traveled too fast for the conditions or was inattentive to condition; and, on the contrary, Plaintiff acted prudently and properly at al1 tinles under the circumstances then existing. In addition, Plaintiff denies that her action is barred or linlited by the limited tort election under the Financial Responsibility Act; and, on the contrary, Plaintiff has sustained serious injuries and damages and is otherwise legally entitled to claim for economic and non-economic damages. ;""" - J..,. , IlIIW.LI;,. , WHEREFORE, Plaintiff requests that New Matter be dismissed and judgment entered in her favor. MORGAN & MORGAN, P.C. By SoW. M Esquire Ir rneys for Plaintiff, C. Hanrmond DATED: January "}o , 2001 ^,," -6 ';'1 ~ VERIFICATION Scott W. Morgan, Esquire states that he is counsel of record for Plaintiff in the within action, is authorized to take this Verification on her behalf, and that the statements made in the foregoing Reply to New Matter are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. ~~, -11 :, "~"i I I I ! ,. CERTIFICATE OF SERVICE I, Scott W. Morgan, Esquire, hereby certifY that service of a true and correct copy of the within Reply to New Matter was made on this :3j}tJ,- day of January, 2001, to the persons below named, by First Class United States Mail, postage prepaid. Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. P. O. Box 1268 Harrisburg, PA 17108-1268 MORGAN & MORGAN, P.C. s~ 120 South Street lIarrisburg,PA 17101-1210 (717) 236-7959 Attorneys for Plaintiff, Carol Hanrmond ~~~~:jJ ~~",M ",~,,,"',,>,","'~ ~ ~. -.,",.~" ." ,>~,,'- ~'''< ,~."-,~-~.~ . ~ ~i'!Illll<i~~>,'<rtu","-~illlMi!l~Uii"Hj,jl.~Jllil'i;it~-~.'--<i'ii>~tit " ,,<<~ - ,,~. .~ ,. o c s= -rJtS (Tlt'!', ~::;) ",_"r G~)",,~. ;:$ ..;:: ",C, -.,,;: 2'0 ':0 -C ~ -< "''''-''''<'' "', c '- .~ ",.,,," '- ",fI -~,,--j;0 ,':::::j(~ .-i- ,.., ~;){':.~J 6rn );;! 5:J -< Co." ..0 .:Jt: ~ ~.n 0'\ .,-- .""""=".'1 . C) "f, ':1 ",-~ " ,I,.. . c i;i' '~<:" , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: .COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/03/2001 ~fpr behalf Of.J1~. rbh.... ~Ft:~ ~~~, . E~~UIa: --~{ Attorney for DEFENDANT DEl1-243664 54490-LOi - "",~~"~.~ .-1",. ~ ^ ;, ,- ~ ",\;,! COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND : TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NO'l'ICB OF INTBN'r TO SBRVE A SUBPOBNA TO PRODUCB DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 FRAlllt S. BRYAN, H.D. DIANE CERUZZI, D.O. HERSHEY MEDICAL CENTER REHAB. CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC PENN'S WOOD PHYSICAL THERAPY TODD L. SAMUELS, H.D. MEDICAL HEDlCAL MEDICAL MEDICAL HEDlCAL MEDICAL MEDICAL TO: SCOTT W. HORGAN, ESQUIRE HCS on behalf of JIU'.l'lSltSON. .J. SHIPMAN, 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 _de, tho tbe subpoena _y be served. Complete copies of any reproduced records _y be ordered at your expense by completing the attached counsel card and returnina ._ to MCS or by contacting our local HCS office. DATE: 03/12/2001 MCS on behalf of .JEFFERSON .J. SHIPMAN, ESQUIRE Attorney for DEPENIiAN'l CC: .JEFFERSOlf.J. SHIPMAN, ESQUIRE - ~ Any questions regarding this _tter, cODtact THE MCS GROUP INC. 1601 HARKET STREET #aoo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-147165 S4490-COl .11 ,~ ' .' "" =.L~,."" "l~';;;'!', I': COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLA.'\'D i~, ! !': CAROL HAMMOND VS CHARLES A. HOCKENBERRY,II File No. 00-8571 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUAAT TO RULE 4009.22 " ,:1 TO: CUSTODIAN OF RECORDS FOR: FRANK S. BRYAN, M.D. (Name of Person or Entity) MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) , :1 I:: II "I " :1 , ;'1 :i1 ::1 Within :Well:)' (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: SEE ATTACHED at 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 ",..onable cost of preparing the copies or producing the things sought. H !~i ::1 i , :1 If you fail to T-oduce the dotuments or things required by this subpoena. within twenty (20) da~'s after its service. the party sen'ing 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: JEFFERSON J. SHIPMAN, ESQ. 1>n RY 1?6l! HARRISBURG, PA 17108 TELEPHONE: 21 ~-246-0qOO SUPREME COURT ID #: ATIOR....EY FOR: DEFENDANT DATE: j'f/arch ~;}ttJI Seal of the Court (Ef!. 7/97) .b ~ '. ,"j--' ~" _.-' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FRANKS. BRYAN, M.D. 19BROOKWOODAVENUE SUITE 104 CARLISLE, P A 17013 RE: 54490 CAROL HAMMOND 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: CAROL HAMMOND . 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 SUlO-294492 54490-LOl CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: _COURT OF COMMON PLEAS CAROL HAI1MOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/03/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-243665 544 9 0 - La 2 . '""1 i I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF IN'1'EN'.r TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 FRANK S. BRYAII, H.D. DIANE CERUZZI, D.O. HERSHEY H1mICAL CENTER 1lEBAB. CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC PENN'S WOOD PHYSICAL THERAPY TODD L. SAHllELS, H.D. H1mICAL H1mICAL H1mICAL H1mICAL H1mICAL H1mICAL H1mICAL TO: SCOTT W. HORGAII, ESQUIllE HCS on behalf of JEFFERSON J. SHIPMAN, 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 HCS or by contacting our local HCS office. DATE: 03/12/2001 HCS on behalf of JEPPERSON J. SHIPMAN, ESQUIU Attorney for DEl'EIlDAIlT CC: JEFFERSON J. SHIPMAN, ESQUIllE - HAHMOND Any questions regarding this matter, contact THE HCS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19101 (215) 246-0900 DE02-147165 54490 - C 01. - ~_L I., " , . "'-~"':: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLA,;'ZD CAROL HAMMOND VS CHARLES A. HOCKENBERRY, It File No. 00-8571 TO: CUSTODtAN OF RECORDS FOR: DR. DIANE CERUZI (Name- of Person or Entity) -~..; ji Ii ,I II ! II " I I II II I i ,I , , I , ! I " I , , i II II ,I " ii " " :i I I I , SUBPOENA TO PRODUCE DOc:tJMEl,;,.S OR THINGS FOR DISCOVERY PURSUA1I.l-r TO RULE 4009.22 Within lWe~' (20) days alter service of this subpoena. you are ordered by the court to produce the following do".."ents or things: SRE ATTACHED al MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Ad_'1 You may dem'" or maUlegible 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 ad,'ance, the reasonable cost of preparing the copies or producing the things _ghL U you fail to ?,oducethe document. or things required by this subpoena. witt-.in twenty (20) day. alter its service. the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF mE FOLLOWING PERSON: SAME: ADDRESS: JEFFERSON J. SHI~. ESQ. PO 'RY 1 'FIR HARRISBURG~ PA 17108 TELEPHOSE: 11 ~-24f\-0900 SUPREME COUltTID II: A TTOR."EY fOR: DEFENDANT DATE: jf)a(c h ~ c9{/l) I BYW~~ lP yj!j~, ~ /~ ~ Deputy' Seal of the Court (Eff. 7/97) H", -I" ,i -'il'l~" EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DIANE CERUZZI, D.O. 1921 SPRING ROAD CARLISLE, PA 17013 RE: 54490 CAROL.HAMMOND 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 SUlO-294494 544 9 0 - L 0 2 ',"--"'~' ~I:.: ~, ' '..,' .ldl:.U;1t, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: -COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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 i. identical to the subpoena which is attached to the notice of intent to serve the subpoena. HCS on behalf of DATE: 04/03/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-243666 544 9 0 -L 0 3 __~a<>>l ~ II ,~ . , L' ~, I""rr" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CuMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF IN'rEN'r TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'rS AND THINGS FOR DISCOVERY PURSUAN'.r.TO RULE 4009.21 FRAHlt S. BRYAN, M.D. DIANE CERUZZI, D.O. HERSHEY MEDICAL CENTER REHAB. CARLISLE HOSPITAL CARLISLE HOSPITAL PAIH CLIRIC PEIIH'S WOOD PHYSICAL THERAPY TODD L. SAMUELS, M.D. MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO: SCOTT W. MORGAN, ESQUIRE MCS on behalf of JEFPEllSOH .J. SHIPKAH, 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: 03/12/2001 MCS on behalf of JEFFERSON .J. SHIPMAII, KSQUI1lE Attorney for DEPElIDAft CC: .JEFPEllSOH.J. SHIPMAR. ESQUIRE - IlA!H)ND Any questions regarding this matter, contact THE MCS GROUP IRC. 1601 MAllKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-147165 54490-C01 ~~ .L b'~~ ,,' ~, "'1'--;;0;;" COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLA.'lD CAROL HAMMOND VS CHARLES A. HOCKENBERRY. II File No. 00-8571 SUBPOENA TO. PRODUCE DOCUMThiS OR THL"lGS FOR DISCOVERY PURSUA1'.;i TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER (Name of Penon or Entity) -.....'-- Within lWe~' (201 days after service of this subpoena. you.are orderM by the court to produce the following documents Dr things: !;F.E ATTACHED MCS GROUP INC.. 1601 MARKET ST.. '800. PRIll. .PA 19103 IAd-, at You may delh'" Dr mail legible copies of the documenll or prod_ ttdngs requested by this subpoena. together with the certificate of compliance, to the party making this requett . 'M ,f L _ Usted above. You have the right to seek. in ad\'ance, the lOuonable cost of preparing the copies d' proohorittt 'M thlnss _ght. U you faillD roducethe documents Dr things required by lhie "'r--- within twenty (20) days after its service, the party sen-ing this subpoelUl may seek a court o.der compellin, yw Ie (_ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOwtNG PERSON: !':AME: ADDRESS: JEFFERSON J. SHIPMAN'; ESQ. pn RY t'''A HARRISBURG. FA 17108 TElEPHOSE: 21 'i-246-0QOO SUPREME COURT ID It: ATIOR."EY FOR: DEFENDANT DATE: flla rC;' 8'i Q2C1O / B4)(1~~ "~.il ivision ~/~~. / Oepuly Seal of ~he Court (Eff. 7/9i) "iiWoW- " -"", EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER REHAB. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 54490 CAROL HAMMOND Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 5U10-294496 544 9 0 -L 0 3 .d>, ^~ I", ,~ '" " ','r-' ~, "'L~., .' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: -COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/03/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-243667 54490-L04 ~ ,h I-~ '~~'" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF, COURT OF COMMON PLEAS CAROL HAMMOND TERM, -vs- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OJ!' n.'J:'I5N"l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEH'rS AND TllINGS FOR DISCOVERY PURSUAlft' TO RULE 4009.21 FRAIlK S. BB-YAII, H.D. DIANE CERUZZI, D.O. HERSHEY MEDICAL CENTEB. REHAB. CAllLISLE HOSPITAL CAllLISLE HOSPITAL PADI CLINIC PENH'S WOOD PHYSICAL TllERAPY TonD L. SAKlJELS, H.n. MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO. SCOTT W. HOB-GAll, ESQUIRE KeS on behalf of JEI!'FERSOIl .J. SHIPMAII, 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 subpoeaa. If the twenty day notice period is ....aived or if no objection is made, thea the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returuina s_ to KeS or by contacting our local KeS office. DATE: 03/12/2001 KeS on behalf of JEI!'FERSOIl .J. SBIPMAII, ESQUIRE Attorney for DEFEllDAIIT CC. .JE1!'FERS01t J~ SIIIPHAIt, ESQUIRE - ~ Any questions regarding this matter, coatact THE KeS GROUP DlC. 1601 MARKET STREET #800 PHILADELPHIA, PA19103 (215) 246-0900 DE02-147165 54490 - C 0 1 ".1J1L~- IM~Ii'i>ffi' COMMONWEALTH OF PENNSYLVANIA - . COUNTY OF CUMBERL.<\;.'m CAROL HAMMOND VS CHARLES A. HOCKENBERRY,II File No. 00-8571 SUBPOENA TO PRODUCE DOCUMTh'TS OR THL'\TGS FOR DISCOVERY PURSU AA'T TO RULE 4009.22 TO: CUSTontAN OF RECORDS FOR: CARLISLE HOSPITAL (Name o( Penon or Entity) Within Merr.y (20) <lays after service of this subpoena. you are or<lered by the court to produce the following document. or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address' You may deliver or mall legible copies of the documents or produce things requested by thi. subpoena, togotMr .11" the certificate of compUance-to the party making this request at the address listed above. You have the right to _.. .ft ad,'ance, the nasonable cost of preparing the copies or producing the things _gilt. If ~'ou fall to ;roo<lu,e the <Iocuments or things require<l by this subpoena. witr.m twenty (20) days after it. ......... t'" patty serving this subpoena may seek a COIUt order compelling you to comply with it.. THIS St.~POENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: N.~e JEFFERSON J. SHI~. ESQ. ADDRESS: PO lIY 1 ?/iR HAlUlISBURG, :PA 17108 TELEPHONe "21 ;-'46-0900 SUPREME COURT IDIi: ATrOR....EY FOR: DEFENDANT DATE: fP~ f (JOO( ~ W-U4. ~. . LCfY Deputy Seal of the Court (Elf 7/97) ~"'~~. . " ", ~~'.~ .~" EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 54490 CAROL HAMMOND Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 SUIO-294498 544 9 0 -LO 4 ,a--'" . ,;I "," ,"" , . ""f'~ "" "~L', CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: .COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/03/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-243668 54490 - LOS "'- I,'. ,,". "..'rtm-' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF. COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO. 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF IN'l'BN'r TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAR'l' TO RULE 4009.21 "FRANK S. BRYAN, K.D. DIANE CEll.UZZI, D.O. HERSHEY MEDICAL CEBTEll. REHAB. CABLISLE HOSPITAL CABLISLE HOSPITAL PAIN CLINIC PENH'S WOOD PHYSICAL TllERAPY TODD L. SAMUELS, K.D. MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO: SCOTT W. HORGAN, ESQUIRE KeS on behalf of JEFFERSON J. SHIPMAN, 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 KCS office. DATE. 03/12/2001 KeS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEP'ENDAII'l cc: JEFFERSOK J. SHIPMAN, ESQUIRE - BAMKOND Any questions regarding this matter, contact THE KeS GROUP INC. 16Q1 MARKET STREET #800 . PHILADELPHIA, PA 19103 (215) 246-0900 DE02-147165 54490-CO::J... '>~'-; w .~ "'~ ' " '~. J' '. ", " I , ""}/ COMMONWEALTH OF PENNSYLV ANIA . COUNTY OF CUMBERLA..~D CAROL HAMMOND VS CHARLES A. HOCKENBERRY,II File No. 00-8571 SUBPOENA TO PRODUCE DOClJMEl,;-rs OR THL'IGS FOR DISCOVERY PURSUAJIi-r TO RULE 4009.22 TO: CUSTODtAN OF RECORDS FOR: CARLISLE HOSPITAL PAIN CLINIC (N~eofPenonorEnd~) -- Within twen:y 1201 days after servke of this subpoena. you are orderlOd by the court to produce the following docit~enis or things: SEE ATTACHED' at MCS GROUP INC., 1601 MARKET ST., '800, PHlLA.,PA 19103 IAddnoo, You may deliver or mail legible copies of the documenll or prod.. things requested by this subpoena. together with the certificate at compliance, to the party making this req_ at the address listlOd above. You have the right to seek. in ad,'ance, the ~uonabJe cost of preparing the copies or produdftS the things saughl. U you faiJ.to jltoduce the documents or things requirltl by thit subpoe..... within twenty (201 days after its service, the party serving this subpoena may seek. court order compelll...,... Ie _ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: ADDRESS: JEFFERSON J. SHI~; ESQ. PO ''AY' l'''A HARRISBURG, PA 17108 TELEPHOSE: 71 'i_246_0CJOO SUPREME COURTID I: ATIOR."EY FOR: DEFENDANT DAre m;~ ? ~()')! BYJ}(f~:t~ ~~. -~)e,/~ /l(). . ~ . Deputy Seal of the Court (Elf. 7/97) .,"'~'w~'~ II .-- L " ';"~" EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL PAIN CLINIC C/O CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 54490 CAROL HAMMOND 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54.3772 Date of Birth: 04-30-1959 SUlO-294500 54490 - LOS .""""'.'..~ . ,I, "n' u. ,...' -,,-,~:sO\ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: _ COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/03/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-243669 54490 -LO 6 a,~ .L. '.' , ~ ~ ;~ ""--'0- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF, COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICB OF IN'l'BNT TO SBRVE A SUBPOENA TO PRODUCB DOCUMBN'1'S AND THINGS FOR DISCOVERY PURSU1W'l' TORULB 4009.21 FRANK S. BRYAN, H.D. DIANE CERUlZI, D.O. HERSHEY MEDICAL CEIITEB. REHAB. CARLISLE HOSPITAL CARLISLE HOSPITAL PAlH CLllUC PENH'S WOOD PHYSICAL THERAPY TODD L. SAMUELS, H.D. MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL . MEDICAL MEDICAL TO: soon w. MORGAN, ESQUIRE HCS on behalf of .J1S1'r'I5KSON J. SHIPMAII, 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 subpoeaa. If tbe twenty day notice period is waived or if no objection is made, thee tbe subpoena may.be served. Complete copies of any reproduced records may be ordered at your ezpense by completing the attached counsel card and returnina .... to MCS or by contacting our local HCS office. nATE: 03/12/2001 MCS on behalf of JEFPERSON J. SHIPMAN, ESQUIU Attorney for DEPEImAN'l CC: JEFPERSOIf J. SHIPMAII. ESQUIRE - IIt.IMlIIIt Any questions.regarding this matter, cootect THE MCS GROUP IHe. 1601 MARlET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-147165 S4490-CO:L . '""~ ~ "J, ~ ~ ~, ~ ~" COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLk'lD CAROL HAMMOND VS CHARLES A. HOCKENBERRY, II File No. 00-8571 SUBPOENA TO PRODUCE DO<:tJMe.1'S OR THL'lGS FOR DISCOVERY PURSUM"T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PENN'S WOODS PHYSICAL THERAPY (N~eofPenonorEnd~} -....; Within lWe~' (20) d.ys after servite of this slIbppona. YOll are ordered by the court to produ<e the following do..,';;ents or things: SEE ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Addre..' .t You m.y deU.'er or mail legible <opies of the doaaments or produ<e things reqaested by this subpoena. together with the certifit.te of complian<e. to the pany making this request at the address listed above. You have the right to seek. in .d,'ance.the ,usonoble <ost of preparing the <opies or p,oduring the things sought. If YOll fail 10 ?"odll<e the doaaments or things required by this sllbpoena. within twenty (20) doys after its servite, the party serving this sllbpoena moy seek 0 <owt order <ampelling YOllto <omply with it. THIS SL'BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: ADDRESS: JEFFERSON J. SHIPMA1ri ESQ. 'Pn ~y 1 '''R. HAlUUSBURG. PA 17108 TEtEPHOSE: ,}l'l-246-0ClOO SUPREME COUllT ID 't ATIOR.'\EY FOR: DEFENDANT DATE: IJJf MLJ3,9(JJf Seal of the Court (Eff. 7/97) ,<,' .,~ w""' "" ~L.' iL ,,; . . '. '~ ' -~:r~ EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DRIVE CARLISLE, PA 17013 RE: 54490 CAROL HAMMOND 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163.54-3772 Date of Birth: 04-30-1959 SUlO-294502 54490-L06 ,~. :,1 ='~iiMlL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: - COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/03/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-243670 54490-LO 7 ",.,,- , aJ " '","-', .' '~ "iOiiii,; COMM.ON\NEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 FRANK S. BRYAN, M.D. DIANE CERUZZI, D.O. HERSHEY MEDICAL CENTER REHAB. CARLISLE HOSPITAL CARLISLE HOSPITAL PAIN CLINIC PENN'S WOOD PHYSICAL THERAPY TODD L. SAMUELS, M.D. MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO: SCOTT W. MORGAN, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, 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: 03{12{2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - HAMMOND Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-147165 54490-COl ';"" "L, I " < i tlill' ~~'j COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLA.~D CAROL HAMMOND VS CHARLES A. HOCKENBERRY,II File No. 00-8571 SUBPOENA TO PRODUCE DOCUME\-rS OR THL'1GS FOR DISCOVERY PURSUAI'-;-r TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: TOPD SAMUELS, M.D, (Name of Perlon or Ezttity} -~ Within lW'~' (20) days alt.r s.rvite of this subpoeN. you are ordered by the court to produce th. following doc"';;.nts or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHlLA..PA 19103 (Ad_., You may d.in.... or maill.gible copies of the docum.nlll or produce things request.d by this subpoen..tog.th.r with th. c.rtificat. of complianc.,to the party making this r.qu.st at the address listed abave. You have the right to s..k. in adunc., th. <tlSOnabl. cost of preparing the copies or producing the things _ght. U you fail to roducethe docum.ntsor things required by lhis subpoena. witl-.in twenty (20) clays alt.r its s.n'ic.. th. party s.rving this subpoena may s...k a court order compelling you to comply with it. THIS StJBPOENA WAS ISSUED AT TIlE REQUEST OF THE FOLLOWING PERSON: SAME: JEFFERSON. J. . SBIPMAN'~ ESQ. ADDRESS: PO RY 1 ?/;R lIAlUUSBURG, PA 17108 TEtEPHOSE: 21 'i-246-OQOO SUPREME COURT 10 It: .f>, lTOR."EY FOR: DEFENDANT DATE: fllauJ !?: ~(kJ! BY~Jll-4 ~ /tJ Pro.~ ~1Jf 'If Deputy Seal of the Court (Eff.7(97) " ~l, .~ I'. ~ ' ~ ~ : ""-~''''''''''~~',:' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TODD L. SAMUELS, M.D. 897 POPLAR CHURCH ROAD SUITE 107 CAMP HILL, PA 17011 RE: 54490 CAROL HAMMOND 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163.54-3772 Date of Birth: 04.30.1959 SU10-294504 54490-L07 ~~~~i,fu;:l},..lm";'M:ili;~j~tI1\,,:(j1 "-'i",,,,''',~hl;lOiIj11Oi!i'''J:!!j'ttUi>fi~i,~'::m'M'Sii'ic.ii,Adi2::Mi''b':;;dj!~.-!!'~IilllJj*OlIll[j_IiiII\lri!6ll_'''''''~ ,,.. ~-'IM'-i.&~~~""" I. " ~~, "',<,'-","",^ ,<I,,,,,,,^ "~ ,~ () ~ Ii{~;:] ;i G'5 e; ;y Z~2? ,,- ~~', ."'~~ "'I .j> "ii I f') [;! i:1 1'1. ): r'! "I 11 [' 1 I I I , i ,: ['I I' .1 "I ,. I (:) ~ ',) -'I !'a. .''''7 ::c:; I C'~ Ii. .~ ~ ';-,;} 2l ~~, ,~,."."" ," .,1', 'I" .., y CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -vs- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/17/2001 \ DEll-246503 544 9 0 - L OB ,,,,,,,,"'- ~= ,--I' '" ,":~ ',,"", " , '~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CAIlLISLE COHKUNITY AMBULANCE .JOAN RICE MILITARY PERSOHllEL RECORDS OTHER MEDICAL EMPLOYMENT TO: SCOTT W. HORGAN, ESQUIRE KGS on behalf of .JEFFERSON .J. SHIPMAII, 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 yourerpense by completing the attached counsel card and returning same to KGS or by contacting our local KeS office. DATE: 03/26/2001 KeS on behalf of .JEFFERSON .J. SHIPMAII, ESQUIRE Attorney for DEPEIIDAHT CC : .JEFFERSON .J. SHIPMAII, ESQUIRE - IIAHKOllD Any questions regarding this matter, contact THE KeS GROUP IIIC. 1601 MARlET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-148434 54490-COl ,~ ;.IJ ~ "";,, I,. " , ,j ,~ ~, COMM.ONVV'EAGH OF PENNSY1. VANIA - COUNTY OF CtlMBERLA.. '-:0 CAROL HAMMOND VS FileNo. 00-8571 CHARLES A. HOCKENBERRY, II SUBPOENA TO PRODUCE DOCUMB-.-rS OR THe'iGS FOR DISCOVERY PURSUA..",-r TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CARLISLE COMMUNITY AMBULANCE SERVICES (Same of Penon or E:u:iry) Within twe~' (10) days after sen-oice of this subpoena. you are ordered by the a:nu1 to produce the following documents or things: C::F.F. A'1''1'Ar.H"F.n MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 al (Adcires.) You may deli,..r or mail legible copies of the documents or produce things requested by this subpoena. together with the certificate of compliance, 10 the party making this request at the address listed above. You have the right to seek. in ad\'ance.tht ,....onable cost of preparing the copies or producing the things sought. If you fail to ,"0 duct the document. or things required by this subpoen,a. within twenty (20) day. after its service, the parry serving this subpoena may seek a court order compelling you to comply with r_ THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JEFFERSON J. SHIPMAN, ESQ. ADDRESS: PO BX 1268 HARRISBURG, PA 17108 TELEPHONE: 215-246-0900 SUPREME COURT 10 It: ATIOR."El fOR.: DEFENDANT BY T DA IE: (Y(';:Mu... :J~ '.:l~1 , '-- Seal of the Court (Elf. i /97) c'._," ',I' l",. --.'>,"'- t _ .'""'':.''''' """"l\1il;l', . EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE COMMUNITY AMBULANCE 102 WEST RIDGE STREET CARLISLE, PA 17013 RE: 54490 CAROL HAMMOND DOl: 3/14/1999, SERVICE #2100224, INCIDENT # 9901116 ANY AND ALL RECORDS Subject: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 SUlO-296832 54490 - L 0 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/17/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-246504 54490 -L 0 9 -~... , '.', <;., i,' ~<,,: '" ,:~' i ,~, "' ...'.; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 CARLISLE COHKUlfITY AMBULANCE JOAN RICE MILITARY PEllSOJlllEL RECORDS OTJIER MEDICAL EMPLOYMEIlT TO: SCOTT W. MORGAN, ESQUIRE KCS on behalf of JEFFERSON J. SHIPMAN, 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 KCS or by contacting our local KCS office. DATE: 03/26/2001 KCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - HAMMOND Any questions regarding this matter, contact THE KCS GROUP INC. 1601 MARKET STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-148434 54490 - C 01 " --- "'lj, ',. , ~ '" ~J' H ~ f COMIv10NWEAL TH OF PENNSYLVANIA COUNTY OF CUMBERLA...'m CAROL HAMMOND VS File No. 00-8571 CHARLES A. HOCKENBERRY, II SUBPOENA TO PRODUCE DOCUME.:.'-l"S OR THINGS FOR DISCOVERY PURSUA.!\l" TO RULE 4009 ,., TO: CUSTODIAN OF RECORDS FOR: JOAN RICE,MSN,CRNP (N.ame of Person 01" Entiry-", \-\~~thin h\.'e:l=!' (20) days after service of this subpoeDA....yo!-lAl:e or.dered by the court to produce the following documents or things: t;t;]<; ATTACHED ML~ uKuur lNG., 1601 MkHKE1 31., #866, ~RILA.,PA 191eJ at (Adc!r"'j 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 aadr-ess listed ~bove. You have the right to seek, in advance. the :easonable cost of preparing the copies or producing the things sought. If you fail to ?=,oduce the documents or things required by this subpoena.. wit:-..in twenty (20) days after its service, the party ser\"ing :h.is subpoena may seek a court order compelling you to comply ",,;th r_ THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: JEFFERSON J. SHIPMAN, ESQ. PO BX 1268 nAKK~~DUKu, ra l'lo~ :lD-:l4b-U~UU TELEPHO~:: SUPREME COliRT ID #: Dt;r ~Nj)AN 1 ATTOR."FY FOR: DATE: ~1lC'J... ~:(, ';) t'Y'>/ Seai or the Coun (Eff. 7/97) .---. - '^' . ~ ~, ' . . L -, ". , " ~ ~ '-'",',,'" ~ j,jo EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOAN RICE MSN,CRNP 49 BROOKWOOD AVE. CARLISLE, PA 17013 RE: 54490 CAROL HAMMOND ANY AND ALL RECORDS. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 SUI0-296834 54490-L09 ,4..,", "JI ,',.. I,' " J -~ CERTIPlCATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 04/17/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-246505 544 9 0 -Ll 0 <~ - ~L , . "'.', : :r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY. II NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 CARLISLE COMMUNITY AMBULANCE JOAN RICE MILITARY PERSONNEL RECORDS OTHER MEDICAL EMPLOYMENT TO: SCOTT W. MORGAN, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, 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: 03/26/2001 MCS on behalf of .JJn"~I!;1tSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - HAMMOND Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-148434 54490-COl ~ , .l~ . ' , ,"" , . """'~~"" COMMONYVEALTH OF PENNSYLVANIA . COUNTY OF CUMBERL..\..'1D CAROL HAMMOND VS file No. 00-8571 CHARLES A. HOCKENBERRY. n SUBPOENA TO PRODUCE DOCUME\1'S OR THINGS FOR DISCOVERY PURSUA.!\;1' TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: ARMY & AIR FORCE EXCHANGE SERVICE (Name of Penon or E..,riry) Within ",'en:;' 110) days aiter service of this subPOSll'll YK~1Atwnred by the court to produce the following documents or things: ~~b ~KUUY LN~.. 1601 l~tI ~I.. #866, YRILA.,PA 13183 at (Addr..,) You may de1h'~ 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 adc:in5s listed above. You ha.....e the right to se~k. in ad...nce. the :easonable cost of preparing the copies or producing the things sought. If ~'ou fail to ?ioduce the documents or things required by this subpoena,. ""itr..in twenty (20) da~'s after its ser..ice, the party sen'ing this s:.;:,poena may seek a court order compelling you to comply with r... THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: ~AME: ADDRESS: JEFFERSON J. SHIPMAN. ESQ. PO BX 1268 ~KL~DU~~, fA 1115a lD-l4.b-U':IUU TELEPHO~E: SUPREME COURT 10 #: DEtIINVAl'I1 A TIOR.'\EY FOR: BY DATh rrz~Ar/.-.. :J ;< I ) ~( Seal of the Court (Eff.7/97) " ,~ ' ,.-'''1;, . a " , ...."'....'" .1;." EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILITARY PERSONNEL RECORDS 9700 PAGE AVENUE ST. LOUIS, MO 63132 RE: 54490 CAROL HAMMOND INCLUDE ALL RECORDS OF EMPLOYMENT FOR CAROL HAMMOND FROM THE ARMY AND AIR FORCE EXCHANGE SERVICE. CARLISLE BARRACKS EXCHANGE. 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 5UlO-296836 544 9 0 - L 10 iIii '''.' w'",-..., lii'NliI'~Wiij;fYjjim~,~~~ii1Ik"lN":',~WlIii!.3j,j:'''''c~"i,;dJi''11W-m$'1i",i:,.1,,;jJffi~~~~i!IHilili:1"'''' . ""~~~~~ ",,~, ".", ,.< ,~"...- ''"', ,. _I 'O,,~. e, =,,",,,. ~,"O ~~', __" ,.,g, .' "..", ~li!'~' flliimI>i o ip ~" fJ~~ !:::;:J (."-; f;:~" ,1," 5S~-:~". ;:>; -"1 -'C, '.' ". :\) C . ~':; . " 0) ,,~,,~~ "E ~' , " I' t: I ! f:i "i r "I;i 'j " li ! r; I' I: I: Ii ~l c_~ ,.,. "I , ~ " ,., '~ 1 ,',' , ;,,_i ..,' C:;"" j, ". CERTIFICATE PREllEQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 08/07/2001 DEll-270977 54490-Lll , ..1" " " ..'" I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'.l' TO RULE 4009.21 PENNSYLVANIA COUNSELING SVS. CHAKBiRSBURG PAIN CLINIC DAVID G. PETKASH, H.D. KEDICAL KEDICAL KEDICAL TO: SCOTT W. MORGAN, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, 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 HCS office. DATE: 07/16/2001 HCS on bel1alf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22740-1043 Any questions regarding this matter, contact THE HCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-159093 54490-C0.1 ,[, , ~ " ' <,', ~,~ COMMO~"WEAL TH OF PENNSYl. VANIA . CGUNTYOFCUMBERL-\..~D CAROL HAMMOND VS FileNo. 00-8571 CHARLES A. HOCKENBERRY II SUBPOENA TO PRODUCE DOCUME-."1S OR THI~GS FO R DISCOVERY PURSU A.l\"1 TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PENNSYLVANIA COUSELING SERVICES {S.me of Prnon or E:uity) ,^'ithin rw-e~'11O) diyS uter service of this subpoeni. you ue ordered by the court to produce the following docu.ments or things: SEE ATTACHED " MCS GROUP INC., 1601 MARKET ST.,1/800, PHlLA.,PA 19103 (.4ddn.., You m,y dein'" or mail legible copies of the document. or produce things requested by thi. .ubpoena. together wit" the certific"e rr. compliance. to the party m&lc.ing this request it the addnss listed above. You han t"e right to ,e.k. in ad,.."ce. the ~..on.ble co.t of preparing the copi.. or producing the thinI' _ght. If you fajJ to ?",oduce the document. or things required by this subpoerl'l. wit.....in twenty (20) cays &it.r its s.".jc.. the party se,,'ing titis ,,,;,poena may seek a cOwf order compelling you to comply with jo_ THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: JEFFERSON J. SHIPMAN, ESQ. 320 MARKET ST.. PO BX 1268 HARRISBURG, PA 17108 TELEPHON:: 215-246-0900 S\;PREME C01.l1lT 10 t: ATIOR....EY FOR: DEFENDANT SAME: ADDRESS: DATE: J[::;. \v <), ~OO I Bbf7u~~~ I'rat....~i.i.. ~t/n?, //p. ^~ Oqury Seal of the Court (:.:f i /97) ,~ 00 .J, L' ,,~ ' , .'j ; ,_,',>- 'J__~b ."'. "fi" EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENNSYLVANIA COUNSELING SVS. 700 CLAY ST. CARLISLE" PA 17013 RE: 54490 CAROL HAMMOND 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 5U10-317128 54490-Lll ,~-' I" '. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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: 08/07/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-270978 S4490-Ll2 ~,~ ~ '1, ~ , ~ ,'-, "', COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICB OF nr.rBNT TO SBRVE A SUBPOENA TO PRODUCB DOCWlBNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PERlfSYLVABIA COUNSELDlG SVS. CBAMBERSBURG PAlII CLI1iIC DAVID G. PETKASIl, H.D. MEDICAL MEDICAL MEDICAL TO: SCOTT W. HORGAN, ESQUIRE MeS on behalf of .J~"ISKSOll :1. SBIPMAlI, 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 retuming same to MeS or by contacting our local MeS office. DATE: 07/16/2001 MeS on behalf of .JEFFEIlSOlI J. SHIPMAlI, ESQUIRE Attomey for DEPEHDAlIT CC: JEPPERSOll :1. SBIPMAlI, ESQUIRE - 22740-1043 Any questions regarding this matter, contact THE MeS GROUP DlC. 1601 IWlXET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-1S9093 54490-CO:l.. ~" ,II ", " " " ,) "<u;a.<.t. '"~'~"< COMMO~'Vv'EALTH OF PENN~YLVANIA CCUNTY OF CUMBERL-\..'iD CAROL HAMMOND VS File So. 00-8571 CHARLES A. HOCKENBERRY II SUBPOENA TO PRODUCE DOCUME\.,.S OR THI:\fGS FOR DISCOVERY PURSUA."'" TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CHAMBERS BURG PAIN CLINIC (S.me of Person or Encity) Wi,hin rw.~' 1::0) d.ys oil.. s.rvi<e of t!tis subpoena. you ue order,"" I:ly the ","un to produce lhe following dacum.n.. ar things: SEE ATTACHED .1 MCS GROUP INC., 1601 MARKET ST..n800. PHILA.,PA 19103 (Ad_I' You m.y deu-'or ar m.i1legible copies of the documents or produce things requesled by l!tis subpoen.. lag.th.r with th. celTifiute of ,ompli.nce. to the pony ",;aking this request.t the .ddress list'"" .boYe. You hove Ihe right to ...k. in ad"..,ce. tho ",..on.ble cost of prep.,;ng Ihe copies or producing Ihe things _gilt. If yau foil te ,"oduc. the documents or t!tingsrequired by t!tis subpoen.l. witJ-.jn twenty (:!O) d.~.s oiler its servi,.. the patTy sen'ing tilislu.poen. m.y seek. cout! order compelling you to comply with r_ THIS St"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: ~AME: JEFFERSON J. SHIPMAN, ESQ. ADDRESS: 120 MARKET gT.. PO BX 1268 HARRISBURG, PA 17108 TELEPHOS:: 215-246-0900 Sl;PRE.\fE COl./1tT 10 f: AITOR.'\EY FOR: DEFENDANT DATE: a"l //. ,;?&?/ ./ BY THE COURT: 15/ tkn;t;;;- ? ~~ PmhonotatylOirk. Civil Divi.ion ~~d y-~ ~ Deputy Sui of the Court C:ff i /97) " ~, L" .'" , . . '~. , 'I ", EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG PAIN CLINIC 112 N. SEVENTH ST. CHAMBERSBURG" PA 17201 RE: 54490 CAROL HAMMOND 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959. 5UlO-317130 S4490-L1Z ~ , ^ ~~< .1 ....' "ltio!:;;,- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DATE: 08/07/2001 DEll-270979 54490-L:L3 ;:1 '. ,',I., " '" 1~'~1i ili!l'I';: CO~ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF IR'rBR'.r TO SERVE A SUBPOENA TO PRODUCE DQC1JlmN'rS AND THINGS FOR DISCOVERY PURSUAN'r TO RULE 4009.21 PERIISYLVANIA COUNSELING SVS. CBAMBERSBURG PAIH CLIHIC .DAVID G. PETKASH, H.D. MEDICAL MEDICAL MEDICAL TO: SCOTT W. HORGAN, ESQUIRE MCS on behalf of JEPFERSOll J. SHIPHAH, 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: 07/16/2001 MCS on behalf of .IundO. J. SHIPMAlI, ESQUIRE Attorney for DEPEIIDART CC: JEFPERSO. J. SHIPHAH, ESQUIRE - 22740-1043 Any questions regarding this matter, contact THE MCS GROUP IHC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-159093 54490-CO:J... ;; - .1, d, ~ t ..' .'- 1->,;, COMMONWEALTH OF PENNSYLVANIA . CCUNTY OF CUMBERL:-\..'I'D CAROL HAMMOND VS File So. 00-8571 CHARLES A. HOCKENBERRY II SUBPOENA TO PRODUCE DOCUMEl.iS OR THINGS FOR DISCOVERY PURSUA.1'I,i TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. DAVID G. PETKASH (S.m.. of Prnon or ElIary) Within rwe~'I::O) days Uter service of this subpoeNl. you ue ordered by the <aurt to produce the following documents or 'hings: SEE ATTACHED il MCS GROUP INC., 1601 MARKET ST. ,1/800, PHlLA. ,PA 19103 I.~dclresl) You may dein'" or moil legible copies of the.doc:umenrs or produ<ethinp req"ested by this subpoen.. logether with the ,.rtifiule a: ,olllpliance. to the potty moJcing this request 01 the addnu listed above. You ha.-e the righl to ..ek. in id"..,ce. the ~uonable cost of preparing lhe copies or produdng the things _gill. If ~'ou fiil to ?",oducethe doc:umenll or things required by this subpoena. wit.""' twenty (:!O) cays Uter its .er,'j,.. the put)' .et\'ing this '~'poena may seek a court order compelling ~'ou to comply with jo_ THIS St'BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: .~DDIlESS: 320 MARKET ST.. PO BX HARRISBURG, PA 17108 TELEPHOSE: 215-246-0900 St.:PRE.\fE COli'RT 10 ,: ....rroll.-;n FOR: DEFENDANT JEFFERSON J. SHIPMAN, ESQ. 1268 DATE: Y'f /1 ~cJc1/ BY THE COURT: L7 /5/ ~. /-'~n PftIthonOWYlOd Civil Divilio. 1";"/1. FX}h; ~ Oepury Seal of the Court (:.ff i/97) ~ , 'j!' ""..:, EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID G. PETKASH, M.D. 890 POPLAR CHURCH RD. CAMP HILL" P A 17011 RE: 54490 CAROL HAMMOND Any and ail. 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: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163.54.3772 Date of Birth: 04-30-1959 SUlO-317132 54490-L13 b '~li.!J i' ""_~l1Rl~lil'!l~~",-<~;4-\.i"riI&o\'i'-i:h-~,!t",,*~,-bbl\\,,~,1i;!ti<lll~lil~~'.i","",,,,~"'''''}i::ffiW\i;,~, '>~,' ^~,".' ...L ~~ -,. ~.,'"""- ,... '"--,,,~,~~,,"'" .,,''',~,., -, <<"I ""-', ,<""~=,':',^,",,, " ,~ ~ . ,,~, ~" ,~ ~~~,'~ alJl!J1 ~~, C) C.:) c: 't: ~ -::J ('\.,1 rflp--; 2}) -:?--n zr": , i' (J)J> \.0 -'.' r-:::; ~Z (~) ~C~ ''0 ?EO :n: C~ ~ (~ --0 i:.') r-n ""e: ,,~ 2: ~. "'2-.-';: =< .0 ~c -< , ^ ,~ ,~" .. "'"-I I I e" ~, .. ^, ,;"'''''''''- ',I' 'i'* " I ~ ~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMl10ND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, 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, (2l 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 (4l The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/20/2001 J A beha7[ 0 ~ SON /t'SHIP ,ES U;~ orney for DEFENDANT MC DEll-292298 54490-L14 ~l' 0',' "~ [, , -I' ~ -'";' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO:' 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF IN'l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUAN'J.' TO RULE 4009.21 SP1UNGo-ROAJ}.FAMILY PRACTICE ROilHEY' HOUGH, M.D. UNlVERSITY PHYSICIANS GROUP MEDICAL MEDICAL MEDICAL TO: SCOTT W. MORGAN, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, 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 tventy day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/29/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT CC: JEFFERSON J. SHIPHAII, ESQUIRE - 22740-1043 Any questions regarding this matter. contact THE MCS GROUP lHC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-168553 S4490-COl -~. .L' !', .j ~ ~,< ~ ~ """'"'~ ~ <~,I...a,L':, COMMONWEAL T,H OF PENNSYLVANIA . COUNTY OF CUMBERLo\.:'iD CAROL HAMMOND VS File No. 00-8571 CHARLES A. HOCKENBERRY, II SUBPOENA TO PRODUCE DOCUMEo..,.S OR THINGS FOR DISCOVERY PURSUA."'" TO RULE 4009.2.2 TO: CUSTODIAN OF RECORDS FOR: SPRING ROAD FAMILY PRACTICE tS..me or Penon otSz2Cicy) .....i:hin lWe~' (:OJ doys Uter service of tltis 5ubpoen.a. you ue ord""" by the ('OUr'lIO producelhe following documenls or .hings: SEE ATTACHED II MCS GROUP INC.. 1601 MARKET STREET. ~mTT"" Rnn. PHTLADELPHIA PA 19103 (Adclresll Vou moy dein'" or mail legible copies of Ihe documenls or producethinp NOlaested by lhis subpoen"logether with the cor'lificote oi rompliance. 10 Ihe parry makinglhis request allhe address listed above. Vou hlIve Ihe righl to seek. in Id...nce. the ~uonable COsl of prepuinglhe copies or producing Ih. thinp -IhL 11 you fail to ?"oduc. the documents or things r.quir.d by tltis subpoena. witr.in twenty {:OJ cays aft.r its 5e,,'ir., the patty 5,,,'ing this 5"~po.na may seek a coun order compelling you 10 comply with i:. THIS SL"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: JEFFERSON J. SHIPMAN, ESQUIRE 320 MARKET ST.. P.O. BOX 1268 HARRISBURG PA 17108 TELEPHON:: (215) 246-0900 SUPREME COURT 10 I: ATrOR.'\n' FOR: THE DEFENDANT NAME: ADDRESS: DATE: r""Y--j- I;(ZO/ZOtJ( ~(j ;lr~ I ~ . BY(E-"2:,"5'k> ~ Pratho_ryiCterlr. Ci ian <... a/2.-~ p ~:~Y".,r---- Seal of the Court (:.fl. i /97) ~~ ~ ,;;I , ,: j'!!iim EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SPRING ROAD FAMILY PRACTICE 1921 SPRING ROAD CARLISLE, PA 17013 RE: 54490 CAROL HAMMOND Any and all recordS, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. ' Dates Requestl!d: from: 03-01-2001 to the present. Subject: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 5U10-335366 54490-L14 ,jJ , ,~ " CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/20/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-292299 54490 -L15 ~'-~' "I. ,,L., ~ ~d,~' '""~",,, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II NOTICE OF HI'.l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 SPRING- ROAD-FAMILY PRACTICE RODNEY HOUGH, M.D. UNIVERSITY PHYSICIANS GROUP MEDICAL MEDICAL MEDICAL TO: SCOTT V. MORGAN, ESQUIRE MCS on behalf of .l1SJ!'1fJY(SON J. SHIPMAN, 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: 10/29/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDAIl'1' CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22140-1043 Any questions regarding this matter, cODtact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DEOZ-l68553 54490-COl. "''''~''' . I , ~~J COMMONWEALTH OF PENNSYLVANIA . COUNr: OF CUMBERL~'it;) CAROL HAMMOND VS File No. 00-8571 CHARLES A. HOCKENBERRY, II SUBPOENA TO PRODUCE DOClJME.',"TS OR l1iI~GS FOR DISCOVERY PURSUA.l\"T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. RODNEY K. HOUGH (S.m. of P.rson or &lcierJ .....ilhin "..e"'Y (:!O) days after s.rvice of this lubpoeN, you ue ordered by the court to produce the (ollowins docum.nts or thins,: SEE ATTACHED at MCS GROUP INC.. 1601 MARKET ~TREF.T. ~T1TTF. ROO. PHILADELPHIA PA 19103 lAd_I' You may dein'" or m~llegible copies of the dOCllmenrs or producethin9 NCl"ested by this subpoena. tos.th.r with the certifica.e ai compliance, to the pony making this request at the adclress lilted above. You ha\..the riShtto 'HI<. in .dunce. tll. ,"uonabl. cost of prrparingthe copies or producing the thinp -shL [f you (ailta ?"oduc.the documents or things rrquir.d by this subpoena. ~Jn lW.nty (::0) da~'s aft.. its I.,,'j... the pury ......ing INs I\.~po.na may seek I court order comp.lling you to comply with it. THIS Sl:BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: JEFFERSON J. SHIPMAN, ESQUIRE 320 MARKET ST.. P.O. BOX 1268 HARRISBURG PA 17108 TELEPHOS:: (215) 246-0900 SUPRE,\fE COURT ID t: ATTOR....EY FOR: THE DEFENDANT SAME: ."OORES!: DATE: ()r-f 1t!-aJ/ZM/ ;;)4 .:)001 , Seal of the Court (':.ff. i /9i\ - ,I;. ~ , ~~h EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RODNEY HOUGH, M.D. 49 BROOKWOOD AVENUE CARLISLE, P A 17013 RE: 54490 CAROL HAMMOND ANY AND ALL REPORTS, DIAGNOSTIC TEST RESULTS & X-RAY REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating' to any examination, consultation, care or treatment. Dates Requested: from: 03-01-2001 to the present. Subject: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 SU10-335974 54490-L15 . ,< ~, ~ , ~ ...., -~,~~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARLES A. HOCKENBERRY, II As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/20/2001 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-292300 54490-L:L6 " i'" ' " ~ ~,-; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CAROL HAMMOND TERM, -VS- CASE NO: 00-8571 CHARI,.ES A. HOCKENBERRY. 11 NO'l'ICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEliI'l'S AND 'l'HINGS FOR DISCOVERY PURSUAliI'l' TO RULE 4009.21 SPIUN~ROAIl-FAHlLY PRACTICE RODNEY HOUGH. M.D. UlfIVERSITY PBYSIClAIIS GROUP MEDICAL MEDICAL MEDICAL TO: SCOTT W. MORGAN. ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAH. 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 ssme to MCS or by contacting our local MCS office. DATE: 10/29/2001 MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE Attorney for DE1'EIIDAIlT CC: JEFFERSON J. SHIPMAB. ESQUIRE - 22740-1043 Any questions regarding this matter. coatact THE MCS GROUP DlC. 1601 MARKET STREET ISOO PHILADELPHIA. PA 19103 (215) 246-0900 DE02-16S553 54490-C01 - ~ ~ , ' "1 < " ~ . , ~l~rlil~' COMMONWEALTH OF PENNSYlVANIA . COUNTY OF CUr;\BERL~~D CAROL HAMMOND VS File No. 00-8571 CHARLES A. HOCKENBERRY, II SUBPOENA TO PRODUCE DOCtJMEl."TS OR TIjL'IGS FOR DISCOVERY PURSUM"T TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: UNIVERSITY PHYSICIANS GROUP (Slome o( Penon 01' !lid,!. Within rw."')' (20) days liter s.rvic. of Utis subpqona. you art ordered by dI. court ro produc. the following docum.nrs or 'hings: SEE ATTACHED .t MCS GROUP INC.. 1601 MARKET ST"RRF.T. ~TTT"F. ROO. PHTT,AnELPHIA PA 19103 (Ad_., You may d.in'" or maill.gibl. copies of the docum.nts or proeluc. thinp nq..esteel by rh.is subpoen..tog.thtr wilh Ih. c."ilica" 0: <ompli~c'.lo Ih. party makinlrhis requestatlh. ael'" Iiaed above. You have the right to seek. in adunce. Ih. :'tuonabl. cost of preparinlthe copies or producinltM tNnp _pi. If you fail to ?,oducethe documents or th.inp required by th.is subpoerY. witr.ift twenty (:!OJ c!a~'s liter ils ..".;... th. parry ",,'inSlhis Sl:~po.na may seek a ccnut order comp.lling you to comply with it. THIS Sl"BPOE!'IIA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: JEFFERSON J. SHIPMAN, ESQUIRE 320 MARKET ST.. P.O. BOX 1268 HARRISBURG PA 17108 TI1.EPHON:: (215) 246-0900 Sl:PREME COt.l1lT ID I: ATrOIl.'\EY FOR: THE DEFENDANT NAME: ADDRESS: OAT!: (')d II /d-.c/.2r>> ( ,;;)4 .:11Y) I . B~~~~ ~JCItr1c. . viaion \... arh.O 2. ~Y:.. r--- Oepu., Seal of the Court (SII. i /97) ~I'L d, - i1~~' EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: UNIVERSITY PHYSICIANS GROUP 3 FLOWERS DRIVE MECHANICSBURG, PA 17050 RE: 54490 CAROL HAMMOND ANY AND ALL REPORTS, DIAGNOSTIC TEST RESULTS & X-RAY REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any exanlination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: CAROL HAMMOND 2310 ENOLA ROAD, CARLISLE, PA 17013 Social Security #: 163-54-3772 Date of Birth: 04-30-1959 SUIO-335976 54490-L16 M '~i!I~~flff~~~1!i~,"i":;!"~lk!'i'"~j,Jii,V-fr.Ww~"~R'~lli\;i',<ih,,,bi"<ilii~iJ.::;i~~Iiiil;WW;li!""'/Ill!~c;;M!li'iIY.>'1I!'- , ,~ ,.' ,,,(1. """""",,' -~ ~1l '( . .," ~ , " " ~; CBr~ 1$,?:: ~.'--" -=::-0 ):.:;. fiE; ~ 2: ....., -< ..... (;:, "~~It' t:::;. ';1" ,:':5 r~.,) '-.i h - ..,. - - ,-, , -'I ....t ",-, , 'jC-; '.};"'"T1 ,~.~](7 i~~~ !t -< ~( 1 T ~ ". , """, "' ~'1 " PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) " TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) x for JURY trial at the next term of civil court. for trial without a jury. . .-------..-.---.----..-.....-----.-----..----..---..---------_...~_._-----_.._._.._--_..._-~--------------~-------.--------------_..._-------.._--_.._~-----~--- r CAPTION OF CASE (entire caption must be stated in full) (check one) Assumpsit Trespass CAROL HAMMOJIlD. (x) Trespass (Motor Vehicle) (Plaintiff) (other) vs. CHARLES A. HOCKEl'lllERRY. II. The trial list will be called on Feb. 12. 2002 and (Defendant) March 11. 2002 Trials commence on .. February 20. 2002 Pretrials will be held on (Briefs are due 5 days before pretrials.) .' vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 8571 Civil "lIJ _~~OO Indicate the attorney who will try case for the party who files this praecipe: Jefferson J. Shipman. Esquire - for the Defendant Indicate trial counsel for other parties if known: Scott W. Morgan. Esquire. for the Plaintiff This case is ready for trial. Signed. Print Name: Tp-f'-fPTc:nn T ~hipm::ln, li'9TlI-I....e 12/19/01 Attorney for: Attoi'ney_.~.r Defendant Date: . ~ "'j"'"," ' ""~o,,, '__,c.'^,O " . ''-''',Y ~ CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on December 19, 2001: Scott W. Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 Attorneys for Plaintiff GOLDBERG, KATZMAN & SHIPMAN, P.C. e on J. ipman, Esquire 320 Market Street Harrisburg, PA 17108 Telephone: (717) 234-4161 Identification No.: 51785 Attorneys for Defendant 57445.1 .:,;.,~-;", l' =1', --~~ '.'~' '_''-'''''''':0' L" " ~, '.~, " 'i~~~:W:~~' ~cin,liiii,c"~r'H'~" ',', '. ,", """,""",,",{< ~~_=-L~, , ''"'" 1'-' ','~~,,,'" ,,~,~, ~, ""- ~ "'I )~! '( I", l~: I',; It:: Ii.! 8i it ,] ':1 il ~i " 0 0 l~ c: '11 s: CJ "to ....-, ~ e'l 9i~H n If;-~ N -,.,rn z:;: ;~~ ~~2,: 0 !<Ci -V ;;~::D ~O :::.: ~-:::? (----') -0 N ;:~rt"l )>C ~ .- j;! z: I:" :< N ~ " , " ," . ,>> ,'~ .,~" ~ ,~o._ , ,'0 ' ," r.. .,c~ __ _~, .,' '" _,'. ,',c .''""'^ CAROL HAMMOND, Plaintiff vs. CHARLES A. HOCKENBERRY, II, Defendant TO THE PROTHONOTARY: ""A""/,,". ' -'.",,: ~,' ',h'i."--=~",,' :, ;J,,,; , .' ,,';-;;j~::: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-8571 Civil Term JURY TRIAL DEMANDED PRAECIPE PLEASE mark the above-captioned matter settled and discontinued. DATE: 74415.1 MORGAN & MORGAN, P.C. By~7!~ Mel ssa M. R vera, Esqulre 120 South Street Harrisburg, PA 17101-1210 Attorneys for Plaintiff '., , .c. h ~r . - ~ '.' , , ',;.., ,~'" ,- If'~(:"~''':'''';'~~~' "~',"', q, ". ,,_ . """ "~""', "'-"'""'""'<' , .,0 '~nrtr'f '"', , ~ ' "" ~, , o c: .~ V!~ rn'-r/ 2~~' 7:::..- U),j" ~- '-::: r:;~ ",-- ifs ~ -< "- " 'I I, ! :1 ]1 '1 o ,'.) ;t>. " ;z, o -n :::.:J . ,~~b:D "',:rm /3:~ 1); =:::1' ,-"'70 t"''inl --::i ;.p. :I:J -< co ;? i\,) :n