HomeMy WebLinkAbout01-03501
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LAW OFFICES OF
DALE E. ANSTINE, P. C.
TWO WEST MARKET STREET
POST OFFICE 80XS62
YORK, PElQiSYLVANIA 174011
1717)646_0606
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
JEANNE M. WEBER
Plaintiff
NO.: 01 - .3S6{
Cu;l'i~
CIVIL ACTION - LAW
v.
MATTHEW JOHN THOMAS
Defendant
JURY TRIAL DEMANDED
NOTWE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
against you 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 default judgment may
be entered against you by the Court without fiuther 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 THIS OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
Two Liberty Street
Carlisle, Pennsylvania 17013
(717) 249 - 3166
1-800-990-9108
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LAW OFFICES OF
DALE E. ANSTINE, P. C.
TWO WEST MARKET STREET
POST OFFICe: SOX 9S~
YORK, PBNNSYLVANIA 17405
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
JEANNE M. WEBER
Plaintiff
NO.:
CIVIL ACTION - LAW
vi.
MATTHEW JOHN THOMAS
Defendant
JURY TRIAL DEMANDED
A VTSO
USTED HA smo DEMANDADO EN LA CORTE. Si usted desea defenderse de las
quejas expuestas en las paginas siguientes, debe tomar acci6n dentro de veinte (20) dias a partir de
la fecha en que recibi6 la demanda y el aviso. Usted debe presentar comparecencia escrita en
persona 0 por abogado y presentar en la Corte por escrito sus defensas 0 sus objeciones alas
demandas en su contra.
Se Ie avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir
en su contra sin mas aviso 0 notificaci6n por cualquier dinero reclamado en la demanda 0 por
cualquier otra queja 0 compensaci6n reclamados por el Demandante. USTED PUEDE PERDER
DlNERO, 0 PROPRlEDADES U OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE.
SI USTED NO TIENE 0 NO CONOCE UN ABOGADO, V AYA 0 LLAME A LA
OFlCINA EN LA DIRECCION ESCRITA ABAJO PARA A VERIGUAR DONDE
PUEDE OBTENER ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
Two Liberty Street
Carlisle, Pennsylvania 17013
(717) 249 - 3166
1-800-990-9108
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;1 LAW OFFICES OF
il DALE E. ANSTINE, P. C.
~! TWO WEST MARKET STREET
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POST OFFICE BOX 952
YOlm, P"'N"N$yrNANiA 1740:;;
'7171646-0606
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
JEANNE M. WEBER
Plaintiff
NO.: () 1.3 sol c;:.;..p .,-.u.,.-
CIVIL ACTION - LAW
v.
MATTHEW JOHN THOMAS
Defendant
JURY TRIAL DEMANDED
COMPLAINT
I. The Plaintiff is an adult individual residing at ISO Pine Tree Road, Orrtanna, P A
17353.
2. The Defendant is a minor individual having a date of birth of March IS, 1984 who
resides at 13 WestwindDrive, Lemoyne, PA 17043.
3. On October 20,2000, the Plaintiff was a passenger in a Ford Ambulance bearing P A
registration plate l4308-MG which was operated by Charles Sherman and owned by Lower
Allen Township.
4. On October 20,2000, the Defendant was the operator a 1999 Volkswagen Passat bearing
P A registration plate BWW -6897 which was owned by and used with the permission of Charles
E. Thomas and Joyce D. Thomas.
5. On October 20,2000 at approximately 5:00 p.m., the Plaintiff was a passenger in the
aforesaid ambulance in the course of her duties as an EMS personnel, and the ambulance was
proceeding on an emergency call with all of its emergency equipment and lights activated.
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LAW OFFICES OF
DALE E. ANSTINE, P. C.
TWO WEST MARKET STREET
POST OFFICE BOXSS2
YORK, PENN"aYLVA.NL>. 1740~
(7'71846-0606
6. At that same time and place, the ambulance was being operated eastbound on State Route
2018, Carlisle Road approaching its intersection with State Route 2033, Creek Road, and was
intending to proceed straight through the intersection.
7. At that same time and place, the operator of the ambulance approached the intersection
with his emergency lights and equipment activated, stopped the ambulance to ensure he could
safely proceed to the intersection, and began to proceed slowly through the intersection.
8. At that same time and place, the Defendant was operating his vehicle northbound on
Creek Road at an excessive rate of speed when he failed to stop or take other evasive action and
collided with the ambulance in the intersection resulting in injuries and damages to the Plaintiff.
9. This accident occurred as a result of the negligence ofthe Defendant and was due
in no manner to any act, or failure to act, on the part of the Plaintiff.
10. This matter is alleged to exceed the applicable limits of arbitration, and a jury trial
is hereby demanded.
II. The negligence of Defendant Thomas consisted of the following:
a) Failing to properly operate and control his motor vehicle;
b) Failing to keep alert and maintain a proper lookout for the presence
of other motor vehicles on the streets and highways;
c) Operating his vehicle in careless disregard for the safety of others and
the Plaintiffin particular, in violation of75 Pa.C.S. g37I4;
d)
Operating his vehicle too fast for the conditions then and there
existing, in violation of75 Pa.C.S. g3361;
e) Failing to yield the right-of-way to the ambulance in violation of75
Pa.C.S. g3325(a); and
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lAW OFFICES OF
DALE E. ANSTINE, P. C.
TWO WEST MARKET STREET
POST OFFICE 60X 9"2
YORK, PENNSYLVANIA 17405
1717)646.0606
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f) Failing to observe the presence of the ambulance within a sufficient
period of time to stop his vehicle before entering the intersection
when the Defendant knew or should have known of the presence of
the ambulance.
12. As a result of the negligence of the Defendant, the Plaintiff suffered
serious and permanent injuries including lumbar sprain/strain, sacroiliac strain, hip pain,
pelvic pain, left knee pain and severe shock to her nerves and nervous system.
13. As a result of the negligence of the Defendant, the Plaintiff was forced to
incur medical bills and expenses for the injuries she has suffered, the cost or reasonable value of
which is, or may be, in excess of the sum recoverable under the Peunsylvania Motor Vehicle
Financial Responsibility Law, and she will continue to incur medical expenses in the future.
14. As a result of the negligence of the Defendant, the Plaintiff has suffered, or may suffer, a
severe loss of her earnings and impairment of her eaming capacity. This loss of income and
impairment of earning capacity has exceeded, or may exceed, the sum recoverable under the
Pennsylvania Motor Vehicle Financial Responsibility Law, and the loss of income and impairment
of earning capacity will, or may, continue in the future.
15. As a result ofthe negligence of the Defendant, the Plaintiff has undergone, and in
the future may undergo, great mental and physical pain and suffering, mental anguish and
humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily
activities, all to her great loss and detriment.
3
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I.AWQFFICESOF
DALE E. ANSTINE, P. C.
TWO WEST MARKET STREET
POST OFFICE: 80X9Sa
YORK, PENNSYLVANIA 17405
(7'71846-0606
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II
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
jUdgment against the Defendant in an amount in excess of the mandatory arbitration limits.
RESPECTFULLY SUBMITTED:
LAW OFFICES OF DALE E. ANSTINE, P.c.
~~;b(/
LeahB. Graff, Esqu. e
Attorney J.D. #29176
Two West Market Street
P.O. Box 952
York, Pennsylvania 17405
(717) 846 - 0606
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LAW OFFICES OF
DALE E. ANSTINE, P. C.
TWO WEST MARKET STREET
POST OFFICE SOX 952
YORK, PENNSYlNANl:A 17405
(717'S46-0606
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VERIFICATION
I HEREBY VERIFY that the information set forth in the foregoing Complaint is true and
correct to the best of my knowledge, information and belief. I understand that any false
statements contained herein are subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn
falsification to authorities.
Date: s/.;z 'i" /0 I
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F: \FILES\DA TAFILE\T ravdoc,cur\723-pt"a. I1mah
Created: 0"fi12/0110:49:13AM
Revised' 07_12/01 10:57:3'1 AM
3090_723
JEANNE M. WEBER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. 01-3501
MATTHEW JOHN THOMAS,
Defendant
JURY TRlAL OF TWELVE DEMANDED
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of
Defendant, Matthew John Thomas, in the above matter. Defendant hereby demands a twelve juror
jury trial in the above captioned action.
~TS""ff!60RFf WilLIAMS & OTTO
George B. Faller, Jr., Esqu'
J.D. No. 49813
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Defendant
Matthew John Thomas
Dated: July 12, 2001
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CERTIFICATE OF SERVICE
I, Melinda A. Hall, an authorized agent for Martson Deardorff Williams & Otto, hereby
certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post
Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Leah B. Graff, Esquire
LAW OFFICES OF DALE E. ANSTINE, P.C.
Two West Market Street
P.O. Box 952
York,PA 17405
MARTS ON DEARDORFF WILLIAMS & OTTO
By m\11 ;AVJl 0. o. (Lhe
Melinda A. Hall
Ten East High Street
Carlisle, P A 17013
(717) 243.3341
Dated: July 12,2001
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-03501 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WEBER JEANNE M
VS
THOMAS MATTHEW JOHN
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
THOMAS MATTHEW JOHN
the
DEFENDANT
, at 1815:00 HOURS, on the 28th day of June
, 2001
at 13 WESTWIND DR
LEMOYNE, PA 17043
by handing to
JOYCE THOMAS, MOTHER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
9.92
.00
10.00
.00
37.92
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R. Thomas Kline
06/29/2001
DALE E ANSTINE
Sworn and Subscribed to before
By:
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me this /r~ day of
q.f1 ~I A.D.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CNIL ACTION - LAW
NO. 01-3501
JURY TRIAL DEMANDED
JEANNE M. WEBER
MATTHEW JOHN THOMAS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that Plaintiff's Interrogatories, Set #1 and Set #2, along with
Plaintiff s Request for Production of Documents were sent to counsel for Defendant by First Class
United States Mail on the below date to the following address:
George B. Faller, Jr., Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, P A 17013
Date: /D<j-ol
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Leah . Graff, EsqUIre $-
Attorney I.D. No. 29176
Attorney for Plaintiff
DALE E. ANSTINE, P. c.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WEBER
Vs.
NO. 013501
THOMAS
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 GEORGE FALLER, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 12/06/01
GEORGE FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET
CARLISLE, PA 17013
717-243-3341
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215)
File #: M281051
By: Christine Janiszewski
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WE13ER
Vs.
THOMAS
No. 013501
TO: LEAH GRAFF
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND TIllNGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the one(s) 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 no objection is
made the subpoena may be served.
Date: 11/13/01
GEORGE FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET
CARLISLE, PA 17013
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS,
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-3336
INC.
.
By: Christine Janiszewski
Enc (s): Copy of sj.ll:)ppena!::,) '.
Counsel return card
File #: M281051
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COMMJNWElILTH OF PENNSYLVANIA
a:xJNl'Y OF CUMBERIAND
WEBER
VS.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PR()()lX;E DOCI..t1ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009. 22
HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL PA 17011-2288
TO: ATTN: MEDICAL RECORDS DEPT
(Nane of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent!'l os~n1(TTACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the docunents or produce things requested h,
this subpoena, together- with the certificate of carpliance, to the party making thi:
request at the address I isted above. You have the right to seek in advance the reasonable
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~enty
(20) days after its serv;ce, the party serving thh subpoena may seek a court orde,-
co:rpelling you to carp1y with it.
THIS SUBPOENA WAS
NAI'E :
ADDRESS:
ISSUED AT THE REOOEST OF THE FOLLOt'IIt-K3 PERSON:
GEORGE FALLER, ESQ
MARTS ON DEARDORFF WILLIAMS
cr~LICLE, r~ 17013
TELEPH:JNE:
SUPREl'E COURT I D #
ATTORNEY FOR:
215-335-3212
49813
DEFENDANT
Seal of the Court
BY THE COURT:
~otL~~CI~:' ~i~ii '~i~i~ion'
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Deputy
M281051-01
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DATE:
(Eff. 1/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports,x~ray r~ports, ?ut~patie~t.records physical
therapy records, and any other l.nformatl.on pertal.nl.ng to:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
---- - - ---- - - --- - -
AI:LFEES 1\1U8TBE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN . COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough searc!?
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
( ) RECORDS
( ) X-RAYS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
Date
Authorized sl.gnature for
HOLY SPIRIT HOSP
CUMBERLAND
M281051-01
*** SIGN AND RETURN THIS PAGE ***
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aHDNWEALTH OF Pfl'lNSYLVANJA
CXXlNl'Y OF aJMBER[AND
WEBER
VS.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PROOlX:E lXlCU'1ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
ORTHO INST OF PENNA, 875 POPLAR CHURCH RD, CAMP HILL PA 17011
TO:
(Ncrne of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent.. os~n1frTACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things, requested hI
this subpoena, together with the certificate of carpliance, to the party making thi,
request at the address listed above. You have the right to seek in advance the reasonablE
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~enty
(20) days after its serv~ce, the party serving thin subpoena may seek a court orde;-
carpelling you to carply with it.
THIS SUBPOENA WAS
NAME:
ADDRESS :
ISSUED AT THE REQUEST OF THE FOlLONING PERSON:
GEORGE FALLER, ESQ
TELEPHONE:
SUPREI"E COORT I D #
ATTORNEY FOR:
MARTSON DEARDORFF WILLIAMS
CARLIOLE, ~A 17013
215-335-3212
49813
DEFENDANT
11 1/6/fJl
BY THE COORT:
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M281051-02
DATE:
Seal of the Court
Deputy
(Eff. , 7/97),
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: ORTHO INST OF PENNA
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIEDPH()'fOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
(
(
PATIENT BILLING
- X-RAYS
RECORDS / XRAYS have been destroyed
Authorized signature for
ORTHO INST OF PENNA
Date
CUMBERLAND
M281051-02
*** SIGN AND RETURN THIS PAGE ***
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CQMKlNWEALTH OF prnNSYLVANIA
axJNl'Y OF aJMBERlAND
. WEBER
VS.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PROOUCE DOCU1ENTS OR lH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
FAMILY MED CTR, 4076 MARKET ST, CAMP HILL PA 17070
TO:
(N<rne of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa.rnent~ osEitin!TIACHED ADDENDUM
at
- MEDICAL LEGAL REPRODUCTIONS,( INC, 4.940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requested h,
this subpoena, together. with the. certificate of. car(lliance, to the party making thi,
request at the address. 1 isted above. You have the right to seek in advance the reasonab IE
cost of preparing the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within t\oienty
(20) days after its serv~ce, the party serving thh subpoena may seek a court orde'-
c.:arpelling you to carp1y with it.
lH I S SUBPOENA WAS I SSUED AT lHE REQUEST OF THE FOLLO'/ I NG PERSON:
~: GEORGE FALLER, ESQ
ADDRESS:
MARTSON DEARDORFF WILLIAMS
CARLISLE, r~ 17013
TELEPHONE:
SUPREI-E roJRT I D #
ATTORNEY FOR:
215-33!o-3<!1.<!
49813
DEFENDANT
DATE:
Sea 1 of the Court
BY THE. c:a.JRT:
(1~A~p'~~L~j~k': ~'i~i l~ivision
Q;il-L t2 ft.t.N..:
M281051-03
'II Ii y'ioi'''-.'
Deputy
(Eff. 7/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: FAMILY MED CTR
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
-- - - ----
CERTIFIED PHOTOCOPIES WILL BE ACCEP'I'ED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced,
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHEtK THE APPROPRIATE BOX):
} RECORDS
} X-RAYS
( ) PATIENT BILLING
( ) RECORDS / XRAYS have been destroyed
Authorized signature for
FAMILY MED CTR
Date
CUMBERLAND
M281051-03
*** SIGN AND RETURN THIS PAGE ***
',+'ff!'iffAll._." ij _~ ~~. '~~_," , .
'l'
~,,~~, ~, -~..
~TH OF pEmSYLVANIA
<XlUNI'Y OF a:JMBERu,No
WEBER
VS.
File No.
013501
THOMAS
SUBPOENA TO PR()()IXE lX)ClJ-ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
LOWER SWATARA EMERG MED, 659 SPRING GARDEN DR, MIDDLETOWN PA 17057
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of Person or Entity)
Within twenty (20) days after. service of this subpoena, you are ordered by the court to
produce the following docunent,,; OSEil:inl1'TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(A~~ess)940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things, requested hi
this subpoena, together with the certificate. of carpliaflce, to the party making thi,
request at the address I isted above. You have the right to seek in advance the reasonab 1E
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within tw.enty
(20) days after its serv;ce, the party serving thh subpoena may seek a court orde"
carpelling you to carply with it.
TIl I S SUBPOENA WAS
NAME:
ADDRESS:
ISSUED AT TIlE REQUEST OF THE FOLLO'/ING PERSON:
GEORGE FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CARLIDLE, rA 17013
215-335-3212
TELEPJ-()NE:
SUPREI"E OOJRT I D#
ATTORNEY FOR:
49813
DEFENDANT
J 1/ 1t'/01
BY THE OOJRT:
eu. ;:'~~~t~ei-.f.'~~i~'i'l-~i~is-ion
0~a~
M281051-04.
DATE:
Seal of the Court
Deputy
(Ef~. 7/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: LOWERSWATARAEMERGMED
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS ,.ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
_m____ __
- -- - -- - -----
CERTIFIE])uPHOTOC<>PIESWlLL BE ACCEPTED IN LIEU OF youR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sear'Ch
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
( ) RECORDS
( ) X-RAYS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
Date
Authorized s1gnature for
LOWER SWATARA EMERG MED
CUMBERLAND
M281051-04
*** SIGN AND RETURN THIS PAGE ***
,.,~~~
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-~ ~-,!
~1-" _~
<nMlNWrnLTH OF PmNSYLV1\NIA
<XXlNl'Y OF aJMRERIAND
WEBER
VS.
File No.
013501
THOMAS
SUBPOENA TO PRODUCE DCO.M:NTS OR TH I NGS
FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22
WEST SHORE ALS SERVICES, 503 N 21ST ST, CAMP HILL PA 17011-2044
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa.rnentl; os~inl~TACHED ADDJENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(1~~s~940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested b\
this subpoena, together with the. certificate of-carpliance, to the party making thi~
request at the address listed above. You have the right to seek in advance the reasonablE
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~enty
(20) days after its serv;ce, the party serving thh subpoena may seek a court orde"
c:arpelling you to carply with it.
TH I S SUBPOENA WAS
NAME:
AOORESS :
ISSUED AT THE REQUEST OF THE FOlLONING PERSON:
GEORGE FALLER, ESQ
MAR~RON DF.ARDORFF WILLIAMS
CARLIOLE, PA 1?013
215-335-3212
TELEPHONE:
SUPREI1: CCUlT 10 #
ATTORNEY FOR:
49813
DEFENDANT
. ..
/1 /IS/01
BY THE COURT:
c,. A' p~ot@~~6tk."~i;il"~i~';~i-~-
G-.y' 12 7h,H,~
M281051-05
DATE:
seal of the Court
Deputy
(Eff. 7/97)
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ADDENDUM TO SUBPOENA
WEBER
va.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: WEST SHORE ALS SERVICES
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS,ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEP'I'ED IN LIEU OF YOUR PERSONAL APPEARANCE.
-- - -- - - -- - - - - - - - --- -- -- --- -- -- ---- -- ----
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ) RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
( ) PATIENT BILLING
( ) RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized s~gnature for
WEST SHORE ALS SERVICES
CUMBERLAND
M281051-05
*** SIGN AND RETURN THIS PAGE ***
',--~~"",,-'1"'\
" 1
COIM)NWEI\LTH OF PrnNSYLVANIA
o:xJNlY OF aJMBERLAND
WEBER
Vs.
File No.
013501
THOMAS
SUBPOENA TO PRoc:xx:E lXlCU1ENTS OR TIl I NGS
FOR DISCOVERY PURSUANT TO RULE 4009. 22
LOWER ALLEN TWP, 1993 HUMMELL AVE, CAMP HILL PA 17011
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of Person or Entity)
within twenty (20) days after service of this subpOena, you are ordered by the court to
produce the following doa.rnent~ ~~in!~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS, c1!cJ~lJs~940 DISSTON ST., PHILA. I PA
You may deliver or mail legible copies of the documents or produce things ,requested bi
thisu subpoena, together with--the certificate of compliance, to the party making thi,
request at the address I isted above. You have the right to seek in advance the reasonab IE
cost of preoaring the copies or producing the things sought.
If you fail to produce the documents or things required by this subpOena within t~enty
(20) days after its serv~ce, the party serving thh subpOena may seek a court orde.'
compelling you to comply with it.
TIllS SUBPOENA WAS
NAME:
ADDRESS:
ISSUED AT TIlE REOOEST OF THE FOlLCWING PERSON:
GEORGE FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CARLIDLE, r~ 17013
TELEPHONE:
SUPREI'E COURT I D#
ATTORNEY FOR:
215-3~5-3L.IL.
.
49813
DEFENDANT
Ii ti5101
BY THE COURT:
..~.R~ ~'
Prothonotar /Cferk,
0'1,,_12 ~
; . .... - . ..... ..,.-~
M281051-06
DATE:
Civil Division
Seal of the Court
Deputy
(Eff. 7/97)
.'~~~---,
.
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: LOWER ALLEN TWP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETSjANYAND ALL MEDICAL ~ECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSiCALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS,AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
- - - - . . ~
- - ___ __ ___n____ _
CERTIFIED PlIOTOCOPIESWILLUE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
-- - -- - - - - - - - - - - - - - ---- - -- - - - - -----------
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
o
(
(
RECORDS
X~RAYS
( ) PATIENT BILLING
( ) RECORDS / XRAYS have been destroyed
Date
Authorized slgnature for
LOWER ALLEN TWP
CUMBERLAND
M281051-06
*** SIGN AND RETURN THIS PAGIE ***
'~WWl'!l""'l-:J;j!J!,
- - '''~-', \,
CQM!oDNWEALTH OF PENNSYLVANIA
mJNrY OF a.JMBE',RUOO)
WEBER
VS.
File No.
013501
THOMAS
SUBPOENA TO PRODUCE D<XU1ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009. 22
PINNACLE HEALTH HOSP, 111 S FRONT ST, HARRISBURG PA 17101
TO: ATTN: PERSONNEL DEPARTMENT
(Ncrne of Person or Ent ity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent" ~:E:ftinl"TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(1~es~r40 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the docunents or produce things requested b,
this ... subpoena, together with. the cert ificate. of carp 1 iance, to the party mak ing th i,
request at the address listed above. You have the right to seek in advance the reasonablE
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~enty
(20) days after its servke, the party serving thin subpoena may seek a court orde"
compelling you to carply with it.
THIS SUBPOENA WAS
NAI-E :
ADDRESS :
ISSUED AT THE REQUEST OF THE FOLLCWING PERSON:
GEORGE FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CARLIOLE, rA 11013
TELEPI-()NE :
SUPR~ COURT I D#
ATTORNEY FOR:
215-335-3212
49813
DEFENDANT
II /i6:' /61
BY THE COURT:
.. {?(".;~~~tt!";#/cJ;~.
Gf'" 0. ~I':. ,
M281051-07
DATE:
Civi 1 Division
Seal of the Court
Deputy
(Eff. 7/97)
ift,;;~fl,
'1"
"'1- I -\
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH HOSP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND .REPORTS
AND PRE-EMPLOYMENT PHYSICALS,WORKMEN'S COMPENSATION CLAIMS MADE,ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANcE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
( ) RECORDS
( ) X-RAYS
( ) PATIENT BILLING
( ) RECORDS / XRAYS have been destroyed
Date
Authorized signature for
PINNACLE HEALTH HOSP
CUMBERLAND
M281051-07
*** SIGN AND RETURN THIS PAGE ***
;,*,~,,1',~';;;~"
~"" " "
~ " .
,. -~
COM!DNWEALTH OF PENNSYLVANIA
axJNl'Y OF CUMBERIAND
WEBER
VS.
File No.
013501
THOMAS
SUBPOENA TO PRoou:::E DCClJoENTS OR n; I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
CHAMBERS BURG HOSP, 112 N 7TH ST, CHAMBERSBURG PA 17201-6005
TO: ATTN: PERSONNEL DEPARTMENT
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa.rnent" ~Eiinl~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS,(INe, ~940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the documents or produce things requested h)
th-issub~a; together with..the certificate.of carpliance, to the party making thi,
request at the address I isted above. You have the right to seek in advance the reasonab IE
cost of preparing the copies or producing the things sought.
1 f you fai I to produce the docunents or things required by this subpoena within t",enty
(20) days after its serv~ce, the party serving thh subpoena may seek a court orde,-
compelling you to carply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLONING PERSON:
NAME: GEORGE FALLER, ESQ
ADDRESS :
TELEPHJNE:
SUPREI1: COURT I D#
ATTORNEY FOR:
MARTSON DEARDORFF WILLIAMS
CARLIOLE, ~A 11013
215 - 3:1 5 -3212
49813
DEFENDANT
'1/ l/i/01'
8Y THE COURT:
(>Li~ -;:~~otL~/t~k,
q"'/f~ (1 ~
I
M281051-08
Civil Division
DATE:
Sea I of the Court
Deputy
(Eff. 1/97)
(l~l;;;<JlJlJI!1!Il!!l', I
-'. ~,,'... ,
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. -,
,-''-'''''''''''~.''''~
-
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALLuMEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS,_WORKMEN' S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPffiS.WILL BE. ACCEPTED IN LffiUOFYOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
( ) PATIENT BILLING
( ) RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized s1gnature for
CHAMBERS BURG HOSP
CUMBERLAND
M281051-08
*** SIGN AND RETURN THIS PAGE ***
-;i"",,-<'i'~~"'"~i.;1l,,
I I
-"
<nM>NWEALTH OF pmNSYLVANIA
COONrY OF CUMBERLAND
WEBER
VS.
Fi 1e No.
013501
THOMAS
SUBPOENA TO PR()()I.X::E lXX:U1ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
EAST PENNSBORO AMBULANCE, 750 S HUMER ST, ENOLA PA 17025
TO: ATTN: pERSONNEL DEPARTMENT
(Nare of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent" OSE~n~TTACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA
Address)
You may deliverer mail legible copies of the documents or produce things requested hI
this subpoena, together with. the certificate of carp 1 iance, to the party mak ing th i,
request at the address listed above. You have the right to seek in advance the reasonablE
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within tw.enty
(20) days after its serv~ce, the party serving thin subpoena may seek a court orde;'
carpelling you to carp1y with it.
TH I S SUBPOENA WAS I SSUED AT THE REQUEST OF THE FOLLO// I NG PERSON:
NAME: GEORGE FALLER, ESQ
ADDRESS :
MARTSON DEARDORFF WILLIAMS
ChRLICLE, ~h 17013
TELF.PI-PNE:
SUPREI"E OOJRT 10#
ATTORNEY FOR:
21o-33o-3:l1:l
.
49813
DEFENDANT
11/ is:/61
BY THE OOJRT:
. ~7'~tth!t~err: ~ivi 1
0. r-' - () 'nwj,,,
Division
M281051-09
DATE:
Seal of the Court
Deputy
(Eff. 7/97)
,q-~",~~>", '-"-'~
,
."""
~""'P""~- ~~
-~'-'-- ",.
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: EAST PENNSBORO AMBULANCE
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS ,HWORKMEN' S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHb'LDING TAXFORMS,AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
-- -- -
- ----
_n_ ___ ____ _ " _' __.___ _______mm____. ,,_,________ m_ ___ _____ ____ __ _ _ __ __ _m_____ _______-
. CERTIFffin PHOTOCOPIES WILL BE ACCEPTElfIN LIEU OF youR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS A VAlLABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
) PATIENT BILLING
) RECORDS-/ XRAYS have been destroyed
X-RAYS
Date
Authorized s1gnature for
EAST PENNSBORO AMBULANCE
CUMBERLAND
M281051-09
*** SIGN AND RETURN THIS PAGE ***
!"~pIJf~:,r_
-
,~ "
.O~r
-.
"'~
a:JMMJNWEALTH OF PENlSYLVANIA
aJUNl'Y OF aJMBERIAND
WEBER
VS.
Fi Ie No.
013501
THOMAS
SUBPOENA TO PRClOlX:E DOCl..l'1ENTS OR 11i I NGS
FOR D I sroVERY PURSUANT TO RULE 4009. 22
FAYETTEVILLE VOL FIRE. 101 W MAIN ST, FAYETTEVILLE PA 17222
TO: ATTN: PERSONNEL DEPARTMENT
(NII11e of Person or Ent ity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunentO'l os~n~tTACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS\A~P4ss~940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested hI
this subpoena, togethecwithu_the cectificate of.~liance, to.the party making thi~
request at the address listed above.' You have the right to seek in advance the reasonablE
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t~enty
(20) days after its service, the party serving thin subpoena may seek a court orde,-
a::rrpelling you to carply with it.
11i I S SUBPOENA WAS I SSUED AT 11iE REQUEST OF THE FOLlCW I NG PERSON:
NAME: GEORGE FALLER, ESQ
ADDRESS: MARTSON DEARDORFF WILLIAMS
CARLIDLE, ~A 17013
TElEPt-KlNE:
SUPREM:: CXlURT I D #
ATTORNEY FOR:
215-335-3212
.
49813
DEFENDANT
II / I~io'l
BY THE COJRT:
(J;;tn 7>,;'" ;(.!..~. h.J
Prothonotary/Cl k~ Civil
~t2~
M281051-10
Division
DATE:
Seal of the Court
Deputy
(Eff. 1/97)
~,~~,
'':'''''''0
"
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-
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: FAYETTEVILLE VOL FIRE
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLD1NG TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF B1RTH: 12/13/50
SSAN: 190427580
- - __m____
----------
CERTIFIED- PHOTOCOPIES WILL BE ACCEJYiED_~1N LIEU OF. YOuR PERSONAL APPEARANCE.
--- - --- - - --- --- - --- - - - - - - --- --- --- - --- --
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE AITACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
(
(
RECORDS
( ) PATIENT BILLING
. ( ) RECORDS ! XRAYS have been destroyed
X-RAYS
Date
Author1zed s1gnature for
FAYETTEVILLE VOL FIRE
CUMBERLAND
M281051-10
*** SIGN AND RETURN THIS PAGE ***
,!f''!lf'''i<=-....,~'"'_ ,~.J
~,~-~,
~, , -,
-
.
-
-. ~
CQ!oMlNWEALTH OF pmNSYLVANIA
COONl'Y OF ClJMBERU;ND
WEBER
VS.
Fi Ie No.
013501
THOMAS
SUBPOENA TO PROOUCE t:XXU1ENTS OR Tl-t I NGS
FOR D I SCCVERY PURSUANT TO RULE 4009. 22
CARLISLE HOSP ADV LIFE SP,.. 246 PARKER ST, CARLISLE PA 17013
TO: ATTN: PERSONNEL DEPARTMENT
(Name of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent>l os~inl~TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONs,(INe, 4940 DISSTON ST., PHILA., PA
Address)
You may deliver or mail legible copies of the doct.ments or produce things requested b\
_ this subpoena. together__withthecertificate oLCOTPliilf\ce. to the party making .thi,
request at the address 1 isted above. You have the right to seek in advance the reasonablE
cost of pre9aring the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within t\'!enty
(20) days after its serv~ce, the party serving thi!'; ~,ubpoena may seek a court orde.-
exnpelling you to COTPly with it.
Tl-tIS SUSPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOw'/ING PERSON:
NAI'E: GEORGE FALLER, ESQ
ADDRESS :
MARTSON DEARDORFF WILLIAMS
CARLIGLE, ~A 17013
215-335-3212
.
TELEPHONE:
SUPREl'E o::lU'lT I D #
ATTORNEY FOR:
49813
DEFENDANT
II/Is/oi
BY THE o::lU'lT:
: (Z,ur~~oL~;dJ~k.
M281051~11
Civil Division
DATE:
Sea 1 of the Court
Deputy
(Eff. 7/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CtJSTODIAN OF RECORDS FOR: CARLISLE HOSP ADV LIFE SP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANYAND ALL MEDICM RECORDS AND REPORTS
AND- PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHH0LDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
. .
.. .'.CERTIFIEDPHOTOCOPIES Wn:CBEACCEPTEb INiiEu OF YOUR PER.SONALAPPEARA.NCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
(
(
RECORDS
( ) PATIENT BILLING
{ } RECORDS /XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
CARLISLE HOSP ADV LIFE SP
CUMBERLAND
M281051-11
*** SIGN AND RETURN THIS PAGE ***
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C(M.I)NWEl\LTH OF pmNSYLVANIA
CXXJNrY OF aJMBERIAND
WEBER
VS.
Fi Ie No.
013501
THOMAS
SUBPOENA TO PROOXE !XX:U1ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
STATE FARM INS CO, ONE STATE FARM DR, CONCORDVILLE PA 19339
TO: ATTN: JOHN ZAMPELLI JR
(N<Ille of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunentl'l OS:Eitinl&fTACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS'(A~~~ss)940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the docunents or produce things requested b)
.. thi ssubpoena,_ toge_ther withe the cl:!rti fi cate ofCCfl'pliance '- . to the partYmak ingth i,
request at the address listed above. You have the right to seek in advance the reasonablE
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within tw.entv
(20) days after its serv~ce, the party serving thin ~,ubpoena may seek a court orde:-
compelling you to comply with it.
TH I S SUBPOENA WAS
NAl'E:
ADDRESS :
I SSUED AT THE REQUEST OF THE FOLLCIN I NG PERSON:
GEORGE FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
CARLIOLE, rA 17013
215-335-3212
49813
TELEPHONE:
SUPREI'E (;()wT 10#
ATTORNEY FOR:
DEFENDANT
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BY THE COURT:
(~~~f~~;;C'l;k,
C)'r--- () 'n0P,:)
Civi 1 Divis.ion
M281051-12
DATE:
Sea 1 of the Court
Deputy
(Eff. 1/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: STATE FARM INS CO
PIP FILE; POL #706 1991 F10 38 A
PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
- - --
___ - _____ - _m _ ______
...CERTIFIEDPHOTOCOpmSwrr-LUEACCEPTED IN LIEltOFYOUR PERSONAL. APPEARANCE..
-- --- - - - --- - -- - --- - -- - - -- - - - - -- - --- -- ---
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
( ) PATIENT BILLING
.. ( ) RECORDS / XRAYS have been destroyed
X-RAYS.
-- .--
Authorized signature for
STATE FARM INS CO
Date
CUMBERLAND
M281051-12
*** SIGN AND RETURN THIS PAGE ***
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~TH OF PENNSYLVANIA
<XlUNl'Y OF aJMBERLI\ND
WEBER
VS.
Fi Ie No.
013501
THOMAS
SUBPOENA TO PROOIX:E DOCl.t1ENTS OR TH I NGS
FOR 0 I SO:>VERY PURSUANT TO RULE 4009. 22
HAALEYSVILLE INS CO,.. PO BOX 1016, MOORESTOWN NJ 08057
TO:
(NM1e of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docunent'l ~:Etinl"TACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS, djcFrfls~ro DISSTON ST., PHILA., ~-----
You may deliver or mail legible copies of the documents or produce things 'requested hi
this subpoena , together_ wi thu;cthe,cert i ficate_ ofccrrpJ i ance, _ to the party mak i ng thi ~
reques-t-- at the address listed above. You have the right to seek in advance the reasonab 1E
cost of preoaring the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within tw.enty
(20) days after its serv~ce, the party serving thh subpoena may seek a court orde.-
c.x::rrpe 11 ing you to carp ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOw'IING PERSON:
~: GEORGE FALLER, ESQ
ADDRESS :
MARTSON DEARDORFF WILLIAMS
CARLIOLB, vA 1~013
215-335-3212
TELEPI-QIlE:
SU'REJ'oE cx:ulT 10#
ATTORNEY FOR:
49'813
DEFENDANT
lOt !//01
BY THE COURT:
C,.. ;;;'~t~1::t;~k.. 'ci'~i.l .Oivision.
01' ,0. 711., II,~ ,
M281051-13.
DATE:
Seal of the Court
Deputy
(Eff. 1/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: HARLEYSVILLE INS CO
ANY AND ALL WORKERS COMPENSATION RECORDS.
INSURED: LOWER ALLEN TOWNSHIP
PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
- ---
CERTIFlEDPHOTOCOPIESWILL:BE ACCEPTEDIN' UEUOFYOlJR PERSONAL APPEARANcE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ . ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
( PATIENT BILLING
(RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
HARLEYSVILLE INS CO
CUMBERLAND
M281051-13
*** SIGN AND RETURN THIS PAGE ***
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Created: 0Ilf20/0101:53:39'PM
Revised:.01l02!0211'13:fllAM
3090.723
JEANNE M. WEBER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO~ 01-3501
MATTHEW JOHN THOMAS,
Defendant
ruRYT~OFTWELVEDEMANDED
ANSWER
TO: JEANNE M. WEBER, PLAINTIFF, and her attorney LEAH B. GRAFF, ESQUIRE
1. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph.
2. Admitted.
3. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph regarding the ownership of the ambulance. All other averments contained in this
paragraph are admitted.
4. Admitted.
5. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averments contained in this
paragraph.
6. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph regarding the intention of the ambulance operator. All other averments contained in this
paragraph are admitted.
7. After reasonable investigation, the answering Defendant is without knowledge or
information sufficient to form a belief as to the truth or falsity of the averment contained in this
paragraph. As a result, Defendant denies all averments contained in this paragraph.
8.-15. Denied.
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WHEREFORE, Defendant demands judgment in his favor and dismissal of Plaintiffs'
Complaint with prejudice.
MARTS ON EARDORFF WILLIAMS & OTTO
By
George B. Faller, Jr.
Attorney J.D. 49813
Ten East High Street
Carlisle, PA 17013-3093
(717) 243-3341
Attorneys for Defendant
Date: January 2, 2001
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VERIFICATION
The foregoing Answer is based upon information which has been gathered by my counsel in
the preparation of the lawsuit. The language of the document is that of counsel and not my own. I
have read the document and to the extent that it is based upon information which I have given to my
counsel, it is true and correct to the best of my knowledge, information and belief To the extent that
the content of the document is that of counsel, I have relied upon counsel in making this verification.
This statement and verification are made subject to the penalties ofl8 Pa. C. s. 94904 relating
to unsworn falsification to authorities, which provides that in knowingly make false averments, I may
be subject to criminal penalties.
~._~
Matthew ~:::~
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CERTIFICATE OF SERVICE
I, David R. Galloway, an authorized agent for MARTSON DEARDORFF WILLIAMS &
OTTO, hereby certify that a copy of the foregoing Answer was served this date by depositing same
in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows:
Leah B. Graff, Esquire
LAW OFFICES OF DALE E. ANSTINE, P.C.
Two West Market Street
P.O. Box 952
York, PA 17405
Dated: January 2, 2002
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JEANNE M. WEBER
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-3501
JURY TRIAL DEMANDED
v.
MATTHEW JOHN THOMAS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the Notice of Deposition was sent by
First Class United States Mail to counsel for Defendant on the below date at the following address:
George B. Faller, Jr., Esquire
Martson, Deardorff, Williams & Otto
TeD East High Street
Carlisle, P A 17013
Date: i-I-)Cf -Od-
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Leah B. Graff, Esquire '
Attorney J.D. No. 29176
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-3501
JURY TRIAL DEMANDED
JEANNE M. WEBER
MATTHEW JOHN THOMAS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the Amended Notice of Deposition
was sent by First Class United States Mail to counsel for Defendant on the below date at the
following address:
George B. Faller, Jr., Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, PA 17013
Date: I.r/:J--O'd-
~6 . !:U/
Leah B. Graff, Esqurre
Attorney J.D. No. 29176
Attorney for Plaintiff
CAW or"CE5 OF
DALE E. ANSTINE, P. c.
'wOW,", M~"'H STRH'
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IN'TRE'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WEBER
Vs.
NO. 013501
THOMAS
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 GEORGE B FALLER, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s) .
Date: 07/09/02
GEORGE B FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET ,-
CARLISLE, PA 17013-3093
717-243-3341
ATTORNEY FOR DEFENDANT
(c
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215)
File #: M288040
By: Christine Janiszewski
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IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
WEBER
Vs.
THOMAS
No. 013501
TO: LEAH GRAFF
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the one(s) 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 no objection is
made the subpoena may be served.
Date: 06/14/02
GEORGE B FALLER, ESQUIRE
MARTSON DEARDORFF WILLIAMS
TEN EAST HIGH STREET
CARLISLE, PA 17013-3093
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-3336
By: Christine Janiszewski
Enc(s): Copy of subpoena(s)
Counsel return card
File #: M288040
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CCMoDNWEALTH OF PE2'lNSYLVANIA
axJNlY OF CUMBEllIAND
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PROCXJCE OOCU1ENTS OR TH I NGS
FOR D I SCOVERY PURSUANT TO RULE 4009.22
SHAFFER ORECCHIA ASSOCS, 650 N12TH ST, LEMOYNE PA 17043
TO:
(Name of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa.rnenti<l csEEirw.T'FACIIED ADDENDUM
at
M~U~~AL L~~AL K~~Kuuu~r~u~~, ~~~, 494U DISSTON ST., PHILA., PA
(Address)
You rray deliver or. mail legible copies of the docunents or produce things requested hI
this subpoena, together with the. certificate of caTllliance, to. the party making thi,
request at the address listed above. You have the right to seek in advance the reasonabl"
cost of preoaring the copies or producing the things sought.
If you fail to produce the docunents or things required by this subpoena within tVJenty
(20) days after its serv~ce, the party serving thin subpoena may seek a court orde;'
carpel1ing you to carply with it.
TH I S SWPOENA WAS
Wl'E:
ADORESS:
ISSUED AT THE REOOEST OF THE FOl.LONING PERSON:
GEORGE B FALLER, ESQ
MARTS ON DEARDORFF WILLIAMS
C'l\RT,TST,F: PI'. 17013-3093
TELEPH:lNE: .
SlPREI'E ccun I D #
ATTORNEY FOR:
21::; 3-3::; 3212
49813
DEFENDANT
DATE: ,-Ju_AJ~ ~L..~()n~
Sea 1 of the rt
M288040-01
(Eff. 1/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: SHAFFER ORECCHIA ASSOCS
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF' BIRTH: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
SHAFFER ORECCHIA ASSOCS
CUMBERLAND
M288040-01
*** SIGN AND RETURN THIS PAGE ***
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CQ!oHlNWEALTH OF PENNSYLVANIA
COUNl'Y OF ~
WEBER
Vs.
File No.
013501
THOMAS
SUBPOENA TO PRODUCE DOCU'ENTS OR THI NGS
FOR DISCOVERY PURSUANT TO RU..E 4009. 22
COWLEY ASSOCS, 425 N 21ST ST, PLZ 21 STE 2-1
CAMP HILL PA 17011
TO:
(Name of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa.rnenti<l mirw.SfTACIIED ADDENDUM:
at
M~U~~AL L~~AL K~~KUUUC1~U~~, ~~~, 4Y4U Ul~~TU~ ~T., ~~lLA., ~A
(Address)
You rray deliver.or mail legible copies of the docunents or produce things requested hI
this subpoena, together with the certifiCate of caTllliance,. to the party making thio.
request at the address listed above. You have the right to seek in advance the reasonablE
cost of preoaring the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within tVJenty
(20) days after its serv~ce, the party serving thin subpoena may seek a court orde"
o:rrpelling you to c:arply with it.
TH I S SUBPOENA WAS
Wl'E:
ADORESS :
ISSUED AT THE REQUEST OF 11iE FOlLONING PERSON:
GEORGE B FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
C'l\RT,TST,F: PA 17013-3093
TELEPHONE:
SlPREI'E a:.utT I D#
ATTORNEY FOR:
213 33::; 3212
49813
DEFENDANT
DATE:..JUA 'J~1_ .,2~ ;;U){);)..
Seal of the rt -
M288040-02
BY
a:.utT:
Prothonotary/Clerk, Civ' 1Vision
aO/hP ./ P. . rym .//...-"n" -' )'
. DepUty
'--....
(Eff. 7/97)
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ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: COWLEY ASSOCS
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL, CT MECHA.NICSBURG PA
DATE OF BIR'1'H: 12/13/50
SSAN: 190427580
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
X-RAYS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
Date
Authorized signature for
COWLEY ASSOCS
CUMBERLAND
M288040-02
*** SIGN AND RETURN THIS PAGE ***
W_~(')1;,
"""T"",
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<XJe.M)NWE2\LTH OF pmNSYLVANIA
COUNl'Y OF ~
WEBER
Vs.
Fi le No.
013501
THOMAS
SUBPOENA TO PROCX..lCE OOCU1ENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
GETTYSBURG HOSP, 147 GETTYS ST BOX 3786, GETTYSBURG PA 17325-0786
ATTN: MEDICAL RECORDS DEPT
(Name of Person or Ent i ty)
TO:
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa.rnenti<l ~iF}tT'FAClIED ADDENDUM:
at
M~J)~~AL L~~AL K~~KUUUC~~O~S, ~~~, 4~4U U~~I;;'!'U~ ~'!'., ~!ULA., I:'~----"
(Address)
You rray deliver or mail legible copies of thedocunentsor produce things requested bl
this subpoena, together. with. the certificate of. caTllliance, to the party making thi:;:
request at the address listed above. You have the right to seek in advance the reasonable
cost of preoaring the copies or producing the things sought.
I f you fai 1 to produce the docunents or things required by this subpoena within tVJenty
(20) days after its service, the party serving thin subpoena may seek a court orde;-
carpell;ng you to carply with it.
1111 S SWPOENA WAS
NAI'E :
ADORESS:
1 SSUEO AT 111E REOOEST OF THE FOl.LON I NG PERSON:
GEORGE B FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
(,l\RT.TST,F:, Pl\ 17013-3093
TELEPH:lNE:
SUPREI'E ccun 10#
ATTORNEY FOR:
,us .33::; 3212
49813
DEFENDANT
M288040-03
BY
DATE: ,
)UDP _ ;Z (", ;) en d-..
Sea I of the Cou~t -
Prothonotary/C erk, 11 Division
~o/JJ!.. 9 ~Q?/JA')(J r--
Deputy
(Eff. 1/97)
-;~'1)j'~iWlli%',,,,,,,,~~_ '."~ "
, ,,~,-
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-
r
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: GETTYSBURG HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray reports, out-patient records physical
therapy records, and any other information pertaining to:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN - COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
X-RAYS
Date
Authorized signature for
GETTYSBURG HOSP
CUMBERLAND
M288040-03
*** SIGN AND RETURN THIS PAGE ***
"-"''''''"'''''''''''''''''_\'~-~~
"
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"
CXJIoM)NWEALTH OF PENNSYLVANIA
a:JUNrY OF aJMBERLAND
WEBER
Vs.
Fi le No.
013501
THOMAS
MEDICAL BILLING REQUESTED
SUBPOENA TO PROOl-a: ooc:u-ENTS OR TH I NGS
FOR D I SO::>VERY PURSUANT TO RULE 4009.22
CAPITAL BLUE CROSS, 2500 ELMERTON AVE, HARRISBURG PA 17177
ATTN: LEGAL DEPT
TO:
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doa.rnenti<l CS:eEinlftTACIIED ADDENDUM
at
- M~Ul.~AL L~~AL K~~KU!Ju~r~u~S, l.~~, 494U !)l.l:;~'!"U~ ~T., Pl:I.l.llA., pa------
(Address)
You may deliver or mail legible copies of the doct..rnents or produce things requested hi
this subpoena, together with the certificate of COllJliance, to the party rooking thi,
request at the address 1 isteo above. You have the right to seek in advance the reasonab I E
cost of preoaring the copies or producing the things sought.
If you fail to produce the doct..rnents or things required by this subpoena within tVJenty
(20) days after its serv~ce, the party serving thin subpoena may seek a court orde;'
o::rrpel1ing you to COllJly with it.
TH I S SWPOENA WAS
Wl'E:
ADORESS :
ISSUED AT THE REOOEST OF THE FOLLONING PERSON:
GEORGE B FALLER, ESQ
MARTSON DEARDORFF WILLIAMS
(,l\RT,TST,F: PA] 7013-3093
TELEPrtJNE :
SlPREI'E COURT I D #
ATTORNEY FOR:
21::;33::; 3212
49813
DEFENDANT
BY
M288040-04
COURT:
DATE: '-
)UD P ::lee. ;:).{)(j d.
Sea 1 of the Court' -
Prothonotary/Clerk,
ho~ P'
"--
(Eff. 1/97)
"'~11','lM\";!'WJ"'l'l!ti,~"" ~ _ ."c..
<".. ~"-
,
, .
ADDENDUM TO SUBPOENA
WEBER
Vs.
No. 013501
THOMAS
CUSTODIAN OF RECORDS FOR: CAPITAL BLUE CROSS
ANY AND ALL MEDICAL BILLS, LIENS AND WORKERS COMPENSATION
INFORMATION. POL #1904275; CONTRACT #020967020
PERTAINING TO:
NAME: JEANNE M WEBER
ADDRESS: 706 OWL CT MECHANICSBURG PA
DATE OF BIRTH: 12/13/50
SSAN: 190427580
MEDICAL BILLING REQUESTED
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN . COMPLETE AND RETURN
RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents ur things ab,:>ve mentioned have been produced.
NO DOCUMENTS A VAlLABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS
X-RAYS
PATIENT BILLING
RECORDS / XRAYS have been destroyed
Date
Authorized signature for
CAPITAL BLUE CROSS
CUMBERLAND
M288040-04
*** SIGN AND RETURN THIS PAGE ***
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JEANNE M. WEBER
v.
MATTHEW JOHN THOMAS
To The Prothonotary:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-3501
JURY TRIAL DEMANDED
PRAECIPE TO REMOVE
(X) Please mark the above captioned action settled and satisfied.
PLEASE ISSUE A CERTIFICATE OF DISCONTINUANCE.
IIc2!-().;l
DATE
,AWO,,"C<5 O'
DALE E. ANSTINE, P. C.
,wo W'S. ~~~.., S'"<E'
POSTO"'CE 00< 9..
YORJ<,PENnsnV"''''AI740''
I~
LAW OFFICES OF DALE E. ANSTINE, P.c.
Respectfully Submitted:
~g.M-
Leah B. Graff, Esquire
Attorney ill No. 29176
Two West Market Street
P.O. Box 952
York, PA 17405
(717) 846 - 0606
Attorney for the Plaintiff
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