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HomeMy WebLinkAbout03-2223RITA ERDMAN, Plaintiff vs. ARTHUR THOMAS DITLOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED PRAEGIPE FQRWRIT OF SU~4~X)NS TO THE PROTHONOTARY: Please issue a Writ of Summons on the above named Defendant. Defendant, ARTHUR THOMAS DITLOW has the following address: Arthur Thomas Ditlow 2315 Kent Street Camp Hill, PA 17011 Respectfully submitted, Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS RITA ERDMAN Plaintiff Vs. Court of Common Pleas ARTHUR THOMAS DITLOW 2315 KEN STREET CAMP HILL PA 17011 Defendant No. 03-2223 In CivilAction-Law To ARTHUR THOMAS DITLOW: You are hereby notified that R/TA ERDMAN the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date MAY 9, 2003 Attorney: Name: MARLIN L. MARKLEY, ESQ. Address: CURTIS R. LONG Prothonotary 2100 MARKET ST., AZTEC BLDG. CAMp HILL PA 17011-4706 Attorney for: Plaintiff Telephone: (717) 763-1800 Supreme Court ID No. 84745 SHERIFF'S RETURN - REGULAR CASE NO: 2003-02223 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ERDMAN RITA VS DITLOW ARTHUR THOMAS GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon DITLOW ARTHUR THOMAS the DEFENDANT , at 1935:00 HOURS, on the 14th day of May at 2315 KENT STREET CAMP HILL, PA 17011 by handing to ARTHUR THOMAS DITLOW a true and attested copy of WRIT OF SUMMONS , 2003 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 10 35 00 10 00 00 38 35 Sworn and Subscribed to before me this /g ~- day of ~ ~.~r.3J A.D. · ~rothonotary ' ' So Answers: R. Thomas Kline 05/15/2003 PATRICK F LAUER ' Deputy Sheriff RITA ERDMAN, Plaintiff VS. ARTHUR THOMAS DITLOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2223 CIVIL ACTION -. LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Arthur Thomas Ditlow, with regard to the above-captioned matter. Date: Respectfully submitted, NEALON & GOVER, P.C. By: Andrew C. Lehman, Esquire I.D. #: 81,937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this ,/'~ day of June, 2003, I hereby certify that I have served the foregoing PF~AECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Marlin L. Markley, Esquire Aztec Building 2100 Market Street Camp Hill, PA 17011 Andrew C. Lehman, Esquire RITA ERDMAN, Plaintiff, V. ARTHUR THOMAS DITLOW, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 03-2223 CIVIL ACTION - LAW PRAEClPE FOR RULE TO FILE COMPLAINT TO THEPROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, Date: NEALON & GOVER, P.C. Andrew C. Lehman, Esquire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. Pr(~thonotary RITA ERDMAN, Plaintiff, ARTHUR THOMAS DITLOW, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 03-2223 CIVIL ACTION - LAW NOTICE TO PLEAD TO: Rita Erdman, and her attorney, Marlin L. Markley, Esquire Aztec Building 2100 Market Street Camp Hill, PA 17011 YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Date: Respectfully submitted, NEALON & GOVER, P.C. By: ~ Andrew C. Lehman, Esquire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 7171232-9900 RITA ERDMAN, Plaintiff, ARTHUR THOMAS DITLOW, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 03-2223 CIVIL ACTION - LAW ANSWER WITH NEW MATTER 1. Admitted upon information and belief. 2.-4. Admitted. 5.-8. Denied as stated. However, it is admitted that on August 12, 2001, at approximately 11:55 a.m. as Defendant Arthur Thomas Ditlow was operating a 1997 Saturn in a northbound direction on North 21st Street in Camp Hill Borough, Cumberland County, Pennsylvania, the front of his vehicle came into contact with the rear of a 2001 Ford Windstar operated by one Steven M. Erdman. As a result of the initial contact between the two aforesaid vehicles, the 2001 Ford Windstar made contact with the rear of Plaintiff's vehicle. The remaining averments contained in these paragraphs are Denied pursuant to Pa.R.C.P. 1029(e). 9. Said Paragraph and all its subparts are denied pursuant to Pa.R.C.P. 1029(e). 10. Said Paragraph is a conclusion of law to which no responsive pleading is required. However, to the extent this Honorable Court deems a response appropriate, the same is denied pursuant to Pa.R.C.P. 1029(e). 11 .-13. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted, and proof is demanded at trial. Any remaining averments contained in these Paragraphs are denied pursuant to Pa.R.C.P. 1029(e). 14. Said Paragraph is a conclusion of law to which no responsive pleading is required. To the extent a response is deemed required, it is denied pursuant to Pa.R.C.P. 1029(e). NEW MATTER 15. Paragraphs 1 through 14 are incorporated herein by reference thereto as if set forth at length. 16. Plaintiff's claims may be barred in whole or in part by operation of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant Ditlow respectfully requests judgment in his favor and that the within Complaint be dismissed with costs. Respectfully submitted, NEALON & GOVER, P.C. Date: Andrew C. Lehman, Esquire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 2 VERIFICATION I, A. THOMAS DITLOW, verify that the statements made in the foregoing ANSWER WITH NEt&/ MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: ~~0~ DITLO~ CERTIFICATE OF SERVICE AND NOW, this ~'_ day of July, 2003, I hereby certify that I have served the foregoing ANSWER WiTH NEW MATTER on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Madin L. Markley, Esquire Aztec Building 2100 Market Street Camp Hill, PA 17011 Andrew C, Lehman, Esquire RITA ERDa_AN, : Plaintiff : : vs. : NO. 03-2223 : ARTHUR THOMAS DITLOW, : CIVIL ACTION - LA~ Defendant : PERSONAL INJURY : JURY TRIAL DF/4A/~DED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA=NIA PLAINTIFF' S ANSWER TO DEFENDANT' S NEW MATTER The Plaintiff, Rita Erdman, by her attorneys, the Law Offices of Patrick Lauer Jr., L.L.Co, respectfully avers the following: 15. Paragraphs 1 through 14 of Defendant's Answer with New Matter are incorporated herein through reference. 16. Denied. This paragraph is a legal conclusion to which no responsive pleading is required. To the extent the allegations are deemed to be factual, the same are denied. WHEREFORE, the Plaintiff, Rita Erdman, respectfully demands judgment against defendant in an amount in excess of the jurisdiction of the compulsory board of arbitrators of this county. Date: Respectfully submitted, .Z/ . ~_ar±~. Mar~±ey, ~squlre 210~ M~rket Street, Aztec Building Camp H~ll, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 RITA ERDMAN, : Plaintiff : : vs. : NO. 03-2223 : ARTHUR THOMAS DITLOW, : CIVIL ACTION - LAW Defendant : PERSONAL INJURY : JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~RIFIC~TION I verify that the statements made in this Answer to New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: Signature: Erdman RITA ERDMAN, : Plaintiff : : vs. : NO. 03-2223 : ARTHUR THOM_AS DITLOW, : CIVIL ACTION - LAW Defendant : PERSONAL INJURY : JURY TRIAL DEM3tNDED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA/~IA CERTIFICATE OF SER"FICE I hereby certify that I am this day serving a copy of the foregoing Answer to New Matter upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States Mail, Camp Hill, Pennsylvania, through certified mail, return receipt requested, prepaid and addressed as follows: Andrew C. Lehman, Esquire Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 Respectfully submitted, , Esquire 210~arket Street, Aztec Building Camp/Hill, Pennsylvania 17011-4706 ID~ ~4745 Tel. (717) 763-1800 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RITA ERDMAN COURT OF COMMON PLEAS TERM, -VS- ARTHUR THOMAS DITLOW CASE NO: 03-2223 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena witi~ a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sou§hr to be served, (2) A copy of the notice of intent, includin§ 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: 09/29/2003 ~ on,pehalf oj~ ~,~,~ Attorney for DEFENDANT DEll-447164 2 4 7 8 O --LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBER]LAND IN THE MATTER OF: RITA ERDMAN -VS- ARTHUR THOMAS DITLOW COURT 0F COMMON PLEAS TERM, CASE NO: 03-2223 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOcuMENTS AND THINGS FOR DISCOVERY PUKS~ TO RULE 4009.21 AMERICAN MEDICAL WOODY'S WEST CUMBERLAND FAMILY PRACTICE CENTRAL PENNSYLVANIA MRI CNTR ORTHOPEDIC INSTITUTE OF PA. DR. SI VAN DO, M.D. KEYSTONE REHABILITATION SYSTEM EMPLOYMENT INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECOPJ]S & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARLIN MARKLEY, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-339 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240687 2 4 7 8 O --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KITA ERDMAN VS. ARTHUR THOMAS DITLOW File No. _ Q3-2223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for AMERICAN MEDICAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouts. Inc._ 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days aRer its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN. ESO. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (2153 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: SEP ]2 9 2003 Seal of the Court Deputy 24780-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: AMERICAN MEDICAL 6011 WILLIAM DRIVE MECHANICSBURG, PA 17055 RE: 24780 RITA C. (ERDMAN) RUCH Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: Up to and including the present. Subject: RITA C. (ERDMAN) RUCH 212 HOLLY DRIVE, CAMP HILL, PA 17011 Social Security #: 183-66-9494 Date of Birth: 08-10-1971 SU10-4~2856 2 4 7 8 0 --LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RITA ERDMAN COURT OF COMMON PLEAS TERM, -VS- ARTHUR THOMAS DITLOW CASE NO: 03-2223 AS a prerequisite to service of a subpoena for documests and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/29/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-447165 24780 --LO 2 COMMONWEALTH OF PENNSYiSVANIA COUNTY OF CUMBERL.AND IN THE MATTER OF: RITA ERDMAN -VS- ARTHUR THOMAS DITLOW COURT OF COMMON PLEAS TERM, CASE NO: 03-2223 NOTICE OF IN~RNT TO .gRWI~E A SUBPOENA TO PRODUCE DOCU~4ENTS ~ FOR DISCOv~KY PIIRSUAITT TO RULE 4009.21 AMERICAN MEDICAL WOODY'S WEST CUMBERLAND FAMILY PRACTICE CENTRAL PENNSYLVANIA MRI CNTR ORTHOPEDIC INSTITUTE OF PA. DR. SI VAN DO, M.D. KEYSTONE REHABILITATION SYSTEM EMPLOYMENT INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RHCORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARLIN MARKLEY, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this' notice. You.have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty' day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: ANDREW C. LEHMAN, PATRICIA HOFFMAN ESQ. - 03-339 Any questions regarding this matter, contact MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240687 24 7 8 O --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RITA ERDMAN VS. ARTHUR THOMAS DITLOW File No. _ 03-2223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WOODY'S WEST (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE AWl'ACHED RIDER **** at The MCS Groun. Inc.. 160l Market S~'eet. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the ceTtificate of compliance, to the party making this request at the address listed above. You have the fight to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena w~tkin twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLO¢~2qG PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. Ese. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 2 9 2003 ! Seal of the Court pr o~onot ary/C~Tr, Civil~ivi sion Deputy 24780-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WOODY'S WEST 3435 SIMPSON FERRY ROAD CAMP HILL, PA 17011 RE: 24780 RITA C. (ERDMAN) RUCH Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates,o.f payments, payee and reasons for payments, including any and all such items stored in a computer database or otherwise in electronic form, pen:aining to: Dates Requested: up to and including the present. Subject: RITA C. (ERDMAN) RUCH 212 HOLLY DRIVE, CAMP HILL, PA 17011 Social Security #: 183-66-9494 Date of Birth: 08-10-1971 Date of Loss: 08/12/2001 SU10-462858 2 4 7 8 0 --LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUA~Ff TO RULE 4009.22 IN THE MATTER OF: RITA ERDMAN COURT OF COMMON PLEAS TERM, -VS- ARTHUR THOMAS DITLOW CASE N0: 03-2223 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been receiv,~d, 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: 09/29/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-447166 2 4 7 80 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMB ERL.AND iN THE MATTER OF: RITA ERDMAN -VS- ARTHUR THOMAS DITLOW COURT OF COMMON PLEAS TERM, CASE N0: 03-2223 NOTICE OF II4T~FT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND FOR DISCOVERY PIFRSUANT TO RULE 4009.21 AMERICAN MEDICAL WOODY'S WEST CUMBERLAND FAMILY PRACTICE CENTP~AL PENNSYLVANIA MRI CNTR 0RTHOPEDIC INSTITUTE OF PA. DR. SI VAN DO, M.D. KEYSTONE REHABILITATION SYSTEM EMPLOYMENT INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARLIN MARKLEY, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this' notice. You'have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty' day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your' expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-339 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240687 24780--CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RITA ERDMAN VS. ARTHUR THOMAS DITLOW File No. _ 03-2223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CLrMBERLAND FAMILY PRACTICE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena; together with the certificate of compliance, to the party making this request at the address listed above. You have the fight to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: t215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Pro~onotary/~e~k, Civ~Division Date: Seal of the Court Deputy 24780-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND FAMILY PRACTICE 4470 VALLEY ROAD ENOLA, PA 17025 RE: 24780 RITA C. (ERDMAN) RUCH Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all suc~h items ,as. may be stored in a computer database or otherwise in electronic ~onn, remtmg to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: RITA C. (ERDMAN) RUCH 212 HOLLY DRIVE, CAMP HILL, PA 17011 Social Security #: 183-66-9494 Date of Birth: 08-10-1971 SU10-462860 24 780--L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUAN~T TO RULE 4009.22 IN THE MATTER OF: RITA ERDMAN COURT OF COMMON PLEAS TERM, -VS - ARTHUR THOMAS DITLOW CASE NO: 03-2223 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/29/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-447167 2 4 7 80 --LO 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMB ERL.kND IN THE MATTER OF: RITA ERDMAN -VS- ARTHUR THOMAS DITLOW COURT OF COMMON PLEAS TERM, CASE NO: 03-2223 NOTICE OF I1TTENT ~) SER~ A SUBPOENA TO PRODUCE DOCUMENTS THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 AMERICAN MEDICAL WOODY'S WEST CUMBERLAND FAMILY PRACTICE CENTRAL PENNSYLVANIA MRI CNTR ORTHOPEDIC INSTITUTE OF PA. DR. SI VAN DO, M.D. KEYSTONE REHABILITATION SYSTEM EMPLOYMENT INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARLIN MARKLEY, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this' notice. You'have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to WCS or by contacting our local MCS office. DATE: 09/08/2003 CC: ANDREW C. LEHMAN, PATRICIA HOFFMAN ESQ. - 03-339 Any questions regarding this matter, contact MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240687 24 780 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RITA ERDMAN VS. ARTHUR THOMAS DITLOW File No. _ 03-2223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CENTRAL PENNSYLVANIA MRI CNTR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving th/s subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN, ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: ~ P~thonolal~l~3~, Ci~ Division Deputy 24780-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTRAL PENNSYLVANIA MRI CNTR 2527 CRANBERRY HWY WAREHAM, MA 02571 RE: 24780 RITA C. (ERDMAN) RUCH Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical repons, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: RITA C. (ERDMAN) RUCH 212 HOLLY DRIVE, CAMP BILL, PA 17011 Social Security #: 183-66-9494 Date of Birth: 08-10-1971 SIJ10-462862 24780 --LO4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RITA ERDMAN COURT OF C0MMON PLEAS TERM, -VS- ARTHUR THOMAS DITLOW CASE NO: 03-2223 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (~) 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: 09/29/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-447165 2 4 7 8 O --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL~kND IN THE MATTER OF: RITA ERDMAN -VS- ARTHUR TEOMAS DITLOW COURT OF COMMON PLEAS TERM, CASE NO: 03-2223 NOTICE OF /i~'r~zTT TO .RI~R%FE A SUBPOENA TO PRODUCE DOCD~ENTS AlqD T~TNGS FOR DISCOVERY Fu~SUANT TO RULE 4009.21 AMERICAN MEDICAL WOODY'S WEST CUMBERLAND FAMILY PRACTICE CENTRAL PENNSYLVANIA MRI CNTR 0RTHOPEDIC INSTITUTE OF PA. DR. SI VAN D0, M.D. KEYSTONE REHABILITATION SYSTEM EMPLOYMENT INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARLIN MARKLEY, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this' notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at you~ expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFMAN - 03-339 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET :~800 P~ILADELPHIA, PA 19103 (215) 246-0900 DE02-240687 24 7 8 O --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RITA ERDMAN VS. ARTHUR THOMAS DITLOW File No. _ 03-2223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian o£Reeords for ORTHOPEDIC INSTITUTE OF PA. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouo. Inc._ 1601 Market Slxeet. Suite 800. Philadelr~hia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the thLngs sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days atler its service, the party serving this subpoena may seek a court order compelling you to enmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SEP 2 9 20 3 Date: Seal of the Court BY Tt~E COURT: /J Pm'~hono~ Civ~t)ivisien Deputy 24780-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA. 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 24780 RITA C. (ERDMAN) RUCI-I Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, histoE/and physical reports, medication/preseription records, medical billing and payment records, x-ray ~ms and tests with subsequent reports, inc.ludin.g a~.y ,and all .suc~h items .as. may be stored in a computer database or omerw~se m e~ectromc ~o .nn., re~atmg. to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: RITA C. (ERDMAN) RUCH 212 HOLLY DRIVE, CAMP HILL, PA 17011 Social Security #: 183-66-9494 Date of Birth: 08-10-1971 SU10-462864 24 780--L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RITA ERDMAN COURT OF COMMON PLEAS TERM, -VS- ARTHUR THOMAS DITLOW CASE N0: 03-2223 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been receiw~d, 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: 09/29/2003 MCS on behalf of ANDRE~ C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-447169 2 4 7 80 --LO 6 COMMONWEALTH OF PENNSY]LVANIA COUNTY OF CUMBERL~ND IN THE MATTER OF: RITA ERDMAN -VS- ARTHUR T~0MAS DITLOW COURT OF COMMON PLEAS TERM, CASE NO: 03-2223 NOTICE OF I~T~TTT0 SERVE A SUBPOENA T0 PRODUCE D0CuMENTSAND · ~TNGS FOR DISCOVERY mu~b-"l/~/T'~ 'i'0 RULE 4009.21 AMERICAN MEDICAL WOODY'S WEST CUMBERLAND FAMILY PRACTICE CENTRAL PENNSYLVANIA MRI CNTR ORTHOPEDIC INSTITUTE 0F PA. DR. SI VAN DO, M.D. KEYSTONE REHABILITATION SYSTEM EMPLOYMENT INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XKAYS MEDICAL RECORDS & XRAYS TO: MARLIN MARKLEY, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You'have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFF~a.N - 03-339 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET :~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240687 24 7 80 --CO I COMMONWEALTIq OF PENNSYLVANIA COUNTY OF CUMBERLAND RITA ERDMAN VS. ARTHUR THOMAS DITLOW File No. _ 03-2223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. SI VAN DO. M.D. (Name of Person or Entity) Within twenty (20) days alter service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days alter its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOg~iNG PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT D #: ATTORNEY FOR: Defendant Date: Seal of the Court pro~oia°~iv~ Division Deputy 24780-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. SI VAN DO, M.D. 175 LANCASTER BLVD P.O. BOX 2028 MECHANICSBURG, PA 17055 RE: 24780 RITA C. (ERDMAN) RUCH Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical repons, medication/prescription records, medical billing and payment records, x-ray fflrns and tests with subsequent repons, including any and all such items as may be stored in a computer database or otherwise in electronic fo .nn,. relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: upto and including the present. Subject: RITA C. (ERDMAN) RUCH 212 HOLLY DRIVE, CAMP HILL, PA 17011 Social Security #: 183-66-9494 Date of Birth: 08-10-1971 SU10-462866 24 7 8 O--L06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSU~NT TO R~/LE 4009.22 IN THE MATTER OF: RITA ERDMAN COURT OF COMMON PLEAS TERM, -VS- ARTHUR THOMAS DITLOW CASE NO: 03-2223 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been receiv.~d, 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: 09/29/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-447170 2 4 7 80 --LO 7 COMMONWEALTH OF pENNSYIbVANIA COUNTY OF CUMBERL3%ND IN THE MATTER OF: RITA ERDMAN -VS- ARTHUR THOMAS DITLOW COURT OF COMMON PLEAS TERM, CASE N0: 03-2223 NOTICE OF INTENT TO SERVE A SUBPOENA TO ]PRODUCE DOcu~qTS AND ~TNGS FOR DISCOVERY muKSUANT TO RULE 4009.21 AMERICAN MEDICAL WOODY'S WEST CUMBERLAND FAMILY PRACTICE CENTRAL PENNSYLVANIA MEI CNTR ORTHOPEDIC INSTITUTE OF PA. DR. SI WAN DO, M.D. KEYSTONE REHABILITATION SYSTEM' EMPLOYMENT INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARLIN MARKLEY, ESQ. MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this' notice. You'have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: ANDREW C. LEHMAN, ESQ. PATRICIA HOFFF~N - 03-339 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regard/ng this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240687 2 4 7 8 O --CO COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KITA ERDMAN VS. ARTHUR THOMAS DITLOW FileNo._ 03-2223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KEYSTONE REHABILITATION SYSTEM (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by t/he court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouo. Inc.. 1601 Market Street. Suite 800. Philadelphia_ PA l!)103 You may deliver or mail legible copies of the documents or produce firings requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena with/n twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant pv~onotaryfCI'd~, Civil ~ivision Date: Seal of the Court Deputy 24780-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KEYSTONE REHABILITATION SYSTEM 665 PHILADELPHIA ST. P.O.BOX 1289 INDIANA, PA 15701 RE: 24780 RITA C. (ERDMAN) RUCH Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records,-x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertain~g to: Date. s Requested: up to and including the present. Subject: RITA C. (ERDMAN) RUCH 212 HOLLY DRIVE, CAMP HILL, PA 17011 Social Security #: 183-66-9494 Date of Birth: 08-10-1971 SU10-462868 24 7 8 0 --LO 7 CRRTIFICATR PR~RROUI$IT~ TO SRRVIC~ OF A SUBPORNA PURSUANT TO RDLE 400~.22 IN THE MATTER OF: RITA ERDMAN ARTHUR THOMAS DITL~IS- COURT OF COMMON PLEAS TERM, CASE NO: 03-2223 AS a prerequisite to Rule 4009.22 MCS (1) A notice attached twenty da served, (2) A copy of attached (3) No object (4) The subpo~ is attach~ DATE: 10/21/2003 service of a subpoena for documents and things pursuant n behalf of ANDREW C. LEHMAN, FSQ. certifies that f intent to serve the subpoena with a copy of the subpoena hereto was mailed or delivered to each party at least prior to the date on which the subpoena is sought to be he notice of intent, including the proposed subpoena, is this certificate, n to the subpoena has been received, and na which will be served is ident!.cal to the subpoena which d to the notice of intent to serve the subpoena. M~CS on behalf of/ Attorney for DEFENDANT DEll-451905 2 4 7 8 O --LO 8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RITA ERDMAN ARTHUR THOMAS DITL0~ COURT OF COMMON PLEAS TERM, CASE NO: 03-2223 NOTICE OF INT]~ THINGS MAGNETIC IMAGING CE TO: MARLIN MARKLEY, MCS on behalf of AN identical to the ~ days from the date undersigned an obje waived or if no obi copies of any repro the attached counse MCS office. DATE: 10/01/2003 CC: ANDREW C. LEHM~ PATRICIA HOFFM~ ~ TO SERVE A SUBPOENA TO PRODUCE DOcuMENTS AND FOR DISCO%~u~Y PURSUia~NT TO RULE 4009.21 ~TRR MEDICAL, BILLING, AND X-RAY(S) ESQ. )EEW C. LEHMAN, ESQ. intends to serve a subpoena ~ that is attached to this notice. You have twenty (26~ Listed below in which to file of record and serve upon the :tion to the subpoena. If the twenty day notice period is ~ction is made, then the subpoena may be served. Complete ~ced records may be ordered at your expense by completing card and returning same to MCS or by contacting our local ESQ. - 03-339 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-243349 24780--CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND, RITA ERDMAN VS. ARTHUR THOMAS iDITLOW File No. 03-2223 SUBI OENA TO PRODUCE DOCUMENTS OR THINGS F( ~R DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Record,, Within twenty (20) days after documents or things: **** at The MCS Grouv. Inc.. You may deliver or mail legi with the certificate of compli~ to seek, in advance, the reaso: for MAGNETIC IMAGING CENTER (Name of Person or Entity) service of this subpoena, you are ordered by the corm to produce the following SEE ATTACHED RIDER **** 601 Market Sheet. Suite 800. Philadelphia. PA 19103 ~le copies of the documents or produce things requested by this subpoena, togethe nee, to the party making this request at the address listed above. You have the righ ruble cost of preparing the copies or producing the things sought. If you fail to produce the doc the party serving this subpoet THIS SUBPOENA WAS ISS~IED AT THE REQUEST / NAME: ANDREW, ADDRESS: 2411 N. FRC HARRISBU] TELEPHONE: (215~ 246-09 SUPREME COURT ID #: ATTORNEY FOR: Dele aments or things required by this subpoena within twenty (20) days after its service a may seek a court order compelling you to comply with it. OF THE FOLLOWING PERSON: LEHMAN. ESQ. NT STREET LG. PA 17110 )0 ~dant OCT 2 ! 2r1)3 Date: .~1~ CLx4- -)L. J t~l~ Seal of the C tort BY THE CO,U~, T: Prothonotary/Clerk, Civil Divis~ Deputy 24780-0: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, pA 17055 RE: 24780 RITA C. (ERDMAN) Please call for prior app: $50.00 for all o, ther pro~ Entire medical, billing, ~ any and all records, con physicians, files, memot medication/prescription: films and tests with subs may be stored fl a comp to any examin,,fion, corn UCH oval for fees in excess of $100.00 for hospitals, iders. nd diagnostic file, including but not limited to · -spondence to and from the consulting a,n,d/or treating reda, handwritten notes, history and ph) sical reports, ecords, medical billing and payment records, x-ray ;quent reports, including any and all such items as ater database or otherwise in electronic form, relating ultation, diagnosis, care or treatment pertaining to: Dates Requested: up t¢ and including the present. Subject: RIT~ C. (ER)MAN) RUCH 21.2 HOLLY II}RIVE, CAMP HILL, PA 17011 Social Se.c. unty #: 183-6~-9494 Date of Bixth: 08-10-19'/1 SU10-466658 24 78 0--I~0 1