Loading...
HomeMy WebLinkAbout01-03758 -,.", ," _ _I .. ,u' ~' ,~ '."c"" -,..,,~.a:!>lo;~' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs No. CC- d'7S'P G'c..)~( L I~ v. CIVIL ACTION - LAW IN TRESPASS MEGAN HOOK, Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons against the Defendant, Megan Hook, who may be served at 4814 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. Respectfully Submitted, Dated: tJ ~ //:) -/; , / By: Jon than . Crist Att LD. No. 29936 P. O. Box 825 Harrisburg, PA 17108-0825 (717) 761-1880 Attorney for Plaintiffs, Terry W. Tingle and Geraldine K. Tingle WRIT OF SUMMONS TO: MEGAN HOOK You = h~'by notffiro lImt T,ny W. Tingl' ond ~ K Ting!' hove commenced an action against you. . ~ _ Dated:, )" ' Df' .1 ~ .J..OO I Curt Long, Protho ry ~~ 8. 7z~A'')t.J eputy Seal of the Court 67412 1i~":i":!"<J!:'-~; 1lif~..'i.L "'~.joj~mjh";ik'i;!'bt!'lj~'f.~'"i,,-,~;%C;:k1J,-"r ,. ".',' "",,-...,.":';I~{ ;~;~~rtrn ",' " ,.j"'iI:!:~l~5l'''''"lWl ~~~ ~"~"llIIljt1t~ ~. ill_liliil.'"-"~ "I j I ,I :1 'I !I ~I t II J (") <:) c~ -W c " ~ ~ :s: (- '?;:) "1J 0:; c:: ~ mrp -(;~ fl ZT -~ h () ZC <Xl 8 ~'5:. ~ a . c:: C~ ........ 8 0 u :1>_ ~~,,, ~~~ ~f~ ........ zl.... W I I )>2 ':.;~ -, - Z ?D C;: Ul ~~ =<! -< () l -- ,~. ,~ ,~, - ""'~' ,~", ,~ ..,.""",,,,..-," J . ~",. . ~ - '......~"..k"'".;:;..o;"'- ~ ' co, '<I: -- - '~";;..'L,'. ,', ,.~" '.'- ,';':~- ~;-,'";,;. .'.; '.,".,,;;;~I;.j - ,,':"'.i..'_::I~";;(;,>>." :,~,.,~,".of.';~",-i'.:;:;;~"-'\'",.~ ~,-:. .:. 'ii.1: tit ;". ,. ., ~.. TERRY W. TINGLE and GERALDINE K. TINGLE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter our appearance on behalf of Defendant, Megan Hook, in the above-captioned action. CALDWELL & KEARNS ~ 7ftf, . McGuire, Esquire torney J.D. No. 73617 Ray J. Michalowski, Esquire Attorney J.D. No. 87135 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Dated: 01-406/26790 .q,,~,,<__ <'''',,'_'' ,."wc,-,o" '''''' ,. -,~. '~~'";J".".. ,c ;;., ,b.>.' "0,' I ~;"",,,~'-.:_/,.:v''';:,,;:Lt,,:':.:,;,'~,:i,yZj,'',, """ .-;:., '" ~. ~ CERTIFICATE OF SERVICE AND NOW, this L day of jdr , 2001, I hereby certifY that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.s. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Jonathan M. Crist, Esquire Latsha Davis & Yohe, P.C. P. O. Box 825 Harrisburg, P A 17108-0825 CALDWELL & KEARNS By: ~ L/v~ I .ii~";~tiiI~~~~M!i~~~~~~~A1iliB'l~_wt~i"i.-=~.~'..i,,"~ " ~ ~~~ ~'. ,'~"- ~,~,~~~ ~, , ~~" ,'. : ~*~" .'"""" S:llifl "~..MilJ'r C) C:) C ~ -" ;;-, , S~t'~ GJ=' f: ~;~ ".. - -,~, "" "<.." i !' ~ rl; ,~ ! '.:1.' I.!I.. i ! [} I. 1 \;.:;, .:",' -";"! =::l """ 'r, -.:;, n[ ""'" '..'~."..~" -,~- ,- ._,-.~.~ ,'" _ -d"'. ~ ",_,:"ck"""- ."'i.<(,,",,~,"~-,.,,::'I,,,.,,:;,, <",',;4'1v;",,;Y':,;'; "0':' ."'_~ ,'_,._ >,'..~ .;.;, '" '~ji ,-41 \ TERRY W. TINGLE and GERALDINE K. TINGLE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED PRAECIPE TO ISSUE RULE TO FILE COMPLAINT TO: CUMBERLAND COUNTY PROTHONOTARY Please issue a Rule upon the Plaintiffs to file a Complaint within twenty (20) days of service of said Rule, or suffer judgment of non pros. ~ Dated: 7ff/ e T cGuire, Esquire ttorney I.D. #73627 3631 North Front Street Harrisburg, P A 17110 (717) 232-7661 .. " TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs v. MEGAN HOOK, Defendant To: Terry W. Tingle and Geraldine K. Tingle c/o Jonathan M. Crist Latsha Davis & Y ohe, P.C. P. O. Box 825 Harrisburg, PA 17108-0825 - - ~' I' <i.'""" ,",'. '''~'''''' ~ "i!~i - -'>, Coo;;" 1.:;';;' ~,' '. ,-'-, ".', ~"-'.~ -' : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term : CNIL ACTION - LAW : IN TRESPASS : JURY TRIAL DEMANDED RULE A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service hereof, or judgment of non pros will be entered against you. Dated: JLAly 9, ;J06 f 01-406/26791 , ,,' iI~~!'i!i~I~~~~~'0(iW(~>'~~f,!!<i..uLll;;!61~~i11'li ;i.>'''- MiJ1;J' ~ ~ '1';;'-"- o ~, QJL- /..--.- ----71 ~;~ ~!:>, .:-/ "'I I;: , f'I . l~ fi Ii .' , .' Ii II II ii Ii I , , , I I c--=-' to:.:, -"""() ~."" :::~ fr.' ~= .' " ~ ""~....... SHERIFF'S RETURN - REGULAR CASE NO: 2001-03758 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TINGLE TERRY W ET AL VS HOOK MEGAN GERALD WORTHINGTON -,n _h ~ ,_~'~ '. "t;g~.J'''~ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS HOOK MEGAN was served upon the , 2001 DEFENDANT , at 1756:00 HOURS, on the 29th day of June at 4814 BRIAN ROAD MECHANICSBURG, PA 17055 MEGAN HOOK by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.82 .00 10.00 .00 34.82 Sworn and Subscribed to before me this 19 ~ day of C)dj ,20-01 c A.D. Ch-- O. /1;r-eR~.-, ~ rothonotary , So Answers: .r~~~~ R. Thomas Kline 06/29/2001 LATSHA DAVIS & YOHE By: ~P.J_ . Deputy Sh ' ff ,....~ I' . ~... ,j .:I ~"" '--.y ". "". ""fiJ..' ~""~~, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA TERRY W. TINGLE and GERALDINE K. TINGLE Plaintiffs No. 01-3758 v. CIVIL ACTION - LAW IN TRESPASS MEGAN HOOK, Defendant JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 1HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717) 249-3166 (800) 990-9108 68403.1 6 ,,", ,~~ " ~. , ,-, k- "", d ,-. I" "'<II r~ L~: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA TERRY W. TINGLE and GERALDINE K. TINGLE Plaintiffs No. 01-3758 v. CIVIL ACTION - LAW IN TRESPASS MEGAN HOOK, Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, COMES, Plaintiffs, Terry W. Tingle and Geraldine K. Tingle, by and through their attorneys, Latsha Davis & Y ohe, P.c., and file the within Complaint against Defendant, Megan Hook, and in support thereof, provides as follows: 1. Plaintiffs, Terry W. Tingle and Geraldine K. Tingle, are adult individuals, husband and wife, residing at 508 East Marble Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Megan Hook, is an adult individual currently residing at 4814 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The facts and circumstances of the accident herein described took place on July 10, 1999, at or about 12:45 p.m. on Central Boulevard at its intersection with Trindle Road in Cumberland County, Pennsylvania. 4. At the aforesaid time and place Plaintiff, Terry W. Tingle was operating his 1997 Saturn Sedan from the Exit Ramp at Route 581 Westbound onto the Southbound lanes of Central Boulevard. 68403.1 ," , ~ :"J;, , , "" ..~-"~,,,~ 5. At the aforesaid time and place Defendant, Megan Hook, was operating a 1995 Mitsubishi Eclipse on the Exit Ramp of 581 Westbound onto the Southbound lanes of Central Boulevard to the rear of Plaintiff, Terry W. Tingle's, vehicle. 6. At the aforesaid time and place after proceeding from the 581 Exit Ramp, Plaintiff, Terry W. Tingle, brought his vehicle to a stop in the far right portion of the Southbound lane of Central Boulevard at its intersection with Trindle Road, intending to make a right turn onto Trindle Road. 7. At the aforesaid time and place, after bringing his vehicle to a stop, Plaintiff, Terry W. Tingle, pul1ed his vehicle forward to view Eastbound traffic on Trindle Road and again brought his vehicle to a stop, when his vehicle was then struck in the rear by the vehicle operated by the Defendant. 8. The aforesaid collision was due to the negligence of the Defendant in the following particulars: (a) failure to keep a careful and diligent watch upon the highway; (b) failure to have her vehicle under adequate and proper control; (c) failure to observe that Plaintiff, Terry W. Tingle, had brought his vehicle to a stop in sufficient time to avoid a collision therewith; (d) inattentively operating her vehicle; (e) operating her vehicle at such a speed or in such a manner that would not permit her to bring her vehicle to a stop within the assured clear distance ahead; and 68403.1 2 ...- ~" ~ c,:. "".'-- ,: 'I" '~'''\:fi'll!illoi~'' (f) driving her vehicle too closely to the vehicle being operated by the Plaintiff, Terry W. Tingle, in violation of 75 Pa. C.S. S 3310. 9. As a result of the collision as aforesaid, Plaintiff, Terry W. Tingle, has suffered certain bodily injury, including but not limited to: (a) bilateral posterior neck pain; (b) bilateral shoulder pain; and (c) aggravation/ extension of preexisting migraine headaches. Count I Terry W. TinllJe v. Megan Hook 10. The allegations of Paragraphs 1 through 9 above are incorporated herein by reference as if fully set out at length. 11. Solely as a result of the negligence of the Defendant as aforesaid, Plaintiff, Terry W. Tingle, has incurred expenses for medical care and treahnent and may be forced to incur additional expenses for medical care and treahnent for an indefinite time in the future. 12. As a result of the negligence of the Defendant as aforesaid, Plaintiff, Terry W. Tingle, has suffered and will continue to suffer great pain, suffering, inconvenience, embarrassment, mental anguish, and loss of the enjoyment of life. 13. As a result of the negligence of the Defendant as aforesaid, Plaintiff, Terry W. Tingle, may, in the future, suffer a loss of wages and earnings. 63400.1 3 '" =" , ,'- ",~,',-' '. L ,.~ '~ _."w"." _'-woo '''-', tllil\$'~,~":"" 14. As a result of the negligence of the Defendant as aforesaid, Plaintiff may suffer a loss of earning power and capacity. Wherefore, Plaintiff, Terry W. Tingle, demands judgment of the Defendant, Megan Hook, in an amount in excess of Twenty-Five Thousand Dollars ($25,000), the amount requiring compulsory arbitration in Cumberland County, Pennsylvania. Count II Geraldine K. TineJe v. Megan Hook 15. Paragraph 1 through 14 above are incorporated herein by reference as if fully set out at length. 16. Solely as a result of the negligence of Defendant as aforesaid, Plaintiff, Geraldine K. Tingle, has been deprived of the care, comfort, and consortium of her husband, Plaintiff, Terry W. Tingle. [the remainder of this page left intentionally blank] 68403.1 4 'c-"_>' '_j. . " ",:j"~ "~ ,; '-". .- '-,,~~<"'" -1:\0, Wherefore, Plaintiff, Geraldine K. Tingle, demand judgment of the Defendant, Megan Hook, in an amount in excess of Twenty-Five Thousand Dollars ($25,000), the amount requiring compulsory arbitration in Cumberland County, Pennsylvania. Respectfully submitted, Date: t)7/2~/ I By: M. Crist, Esq. A ey No. 29936 P.o. Box 825 Harrisburg, PA 17108-0825 (717) 761-1880 Attorneys for Plaintiffs, Terry W. Tingle and Geraldine K. Tingle 68403.1 5 "".. - ",'" ',~, " ,'..1,' ,'.'. ,-.;:: ~. ,; " ~ "j, '" ""_~~":i :" :_- -~ ~' " ow.""" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE and GERALDINE K. TINGLE Plaintiffs No. 01-3758 v. CIVIL ACTION - LAW IN TRESPASS MEGAN HOOK, Defendant JURY TRIAL DEMANDED VERIFICATION The above COMPLAINT is based upon information which I have furnished to my counsel and information which has been gathered by my counsel in preparation of this matter. The language of the COMPLAINT is that of counsel and not of me. I have read the COMPLAINT and to the extent that the, COMPLAINT 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. COMPLAINT is that of counsel, I have relied upon counsel in making this verification. I hereby acknowledge that the facts set forth in the aforesaid. . COMPLAINT are made subject to penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: 1/;;1I; /b I , #~ ?; ~'- Terry W. . Ie ... 68247.1 "'''''~ ,-.. ......j., _.~,J~ _'_ '_"c.', ,',,,, '~do-c, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE and GERALDINE K. TINGLE Plaintiffs No. 01-3758 v. CIVIL ACTION - LAW IN TRESPASS MEGAN HOOK, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing document was served by first-class United States mail, postage prepaid, upon the following: Jeffrey T. McGuire, Esq. Caldwell & Kearns 3631 North Front Street Harrisburg, P A 17110 Dated: t-I /t9.:5) (j ) /Du;mo..h (J. Gli-J /IA){f")0 Deborah A. Peterson Legal Secretary 68403.1 i':'::"~" cid~~~~_~~.!:,ijJi4';!'i1lil:'W",;d<;:f~Ji~'if,';i,"""M;;;'jjj~f1"'"!!!'l'J>i~W-Jlil":~~';";-.tif;~ fft,~x,_ -g<.- ",., , _,,,,,, ,0 ~~ >" ., ", e~"'.~"- - '" ."~ ~~ ... ,,~^ iml "",=' !I ~ I, I I c' ~,., ..;r ,- -~:-, '"--~ - )..J r- :',~ - 0 ~ '" ""< (J, - f'" -V .:j - ~ - -"... "- " -, ~,'~.> '0'_ __,,1:- .>, ., .C."'_> ,.r,'",,', '"l:,,~:.o, .._:~, <, - ;, .~ . , ~__ "'~'i~" ' ",-,y~" '-"\1 . TERRY W. TINGLE and GERALDINE K. TINGLE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRlAL DEMANDED NOTICE TO PLEAD TO: Terry W. Tingle and Geraldine K. Tingle, Plaintiffs c/o Jonathan M. Crist, Esquire Latsha Davis & Yohe, P.C. P. O. Box 825 Harrisburg, P A 17108-0825 YOU ARE HEREBY NOTIFIED, that the New Matter 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. CALDWELL & KEARNS By: Dated: August 8, 2001 ~ J ~, __~ _ - , ~~"~,.,,,{~, ,~I.: '-",',c, '~""".' k.O___ ;"'__"." \-~;j , TERRY W. TINGLE and GERALDINE K. TINGLE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED ANSWER WITH NEW MATTER AND NOW, comes Defendant, MEGAN HOOK, by and through her attorneys, CALDWELL & KEARNS, and responds to plaintiffs complaint as follows: All averments that maybe denied generally pursuant to Pa. R.C.P. 1029 (e) are hereby denied. NEW MATTER 1. Plaintiffs' claim is barred in whole or in part by provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 2. Plaintiffs' injuries pre-existed the motor vehicle accident which is the subject of Plaintiffs' complaint. 3. In accordance with S 1722 of the Pennsylvania Motor Vehicle Financial Responsibility law, Plaintiff is not entitled to recover any sums paid or payable from any group plan or other arrangement from this Defendant. J. -L,.... ,"'t.'<_ .,..,,'''''.:...._~,':b,.., '-.'" " J: ":,':';,,;.;L i...~" , 4. Plaintiff fails to plead whether she was bound by the limited tort or full tort option on the date of the accident, and ifIimited tort applies, Plaintifffailed to plead an exception to the rule prohibiting recovery of non-economic damages in accordance with 75 Pa. C.S.A. 91705. 5. Defendant specifically preserves those defenses of contributory/comparative negligence and assumption of risk under Pa. R.C.P. 1030. WHEREFORE, Defendant demands that the complaint be dismissed and judgment entered in his favor and against the Plaintiff without cost to him but together with such costs, expenses and attorneys fees as authorized by law and which the Court deems necessary, just and appropriate under the circumstances. BY: Je urre, Esqurre Atty.ld No. 73617 Ray 1. Michalowski, Esqurre Atty. Id. No. 87135 Attorneys for Defendants 3631 North Front Street Harrisburg, P A 1711 0 (717) 232-7661 Dated: (f.{.~ w;j-COt lAM r 'TV'" I "..'.-- .."> . "'" "I" ;..-. . I . .'~' A1~ VERIFICATION I, MEGAN HOOK, verifY that the averments in this Answer with 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. By: 4tu? i. jekJU Dated: /tUQ uS t; 8, ;LOa I v " ~" '-",'. "'j,. ,',- , ' ,...,; - ~ ,: ;:.]'. ,~ ' -,,_ /';, '; 'X'. iK;i; CERTIFICATE OF SERVICE AND NOW, this t'b day of t1u~ ,2001, I hereby certify that I have served a copy ofthe within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Jonathan M. Crist Latsha Davis & Yohe, P.C. P. O. Box 825 Harrisburg, P A 17108-0825 CALDWELL & KEARNS By: ~.>/fJ7~ -'; ~iSuimt '. " ..~~tf~:~~.~~fi,~4~'\llii"t#2ii;l~~~~~.si>!!l: i r,' .. r '~11 0::' ;;.[,' -', ,.~ ~ ....l ,,~ -~< ,- ,,'''~' """""",,,,,,,,,,,-.,.,,. ~ ....~h... ',',.".~j 0 CJ 0 C "'n -oLt )> c:: nlm c;') :r1 Z::-...:) r- Zl-~ I ..',,!~"l ~,~:~~ \D ":jl.J C:O ~ '-.~~(~ -.,-::; :' --j Z;:':i =~ ~~~3 :i> ,~I CO ":-'rn r' 0 ~ 2:: c:.n ~ ~ 5:; -< . , , ' ~~ -",,"' .<"-,>",'" ':j ,'-' :1 ..,.... , ",,~,,< " ,;.; ,-,',,' .',', ''''.''',,' ..., """"'-',,,." " '"j"~;! TERRY W. TINGLE and GERALDINE K TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED CERTIFICATE PREREOUlSITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant Megan Hook certifies that: (I) a notice of intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoenas are sought to be served; W AlVED BY COUNSEL, see waiver attached; (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate; (3) no objection to the subpoenas has been received; and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Date: ~~.(g . 0 ( ~~~- At eyfOI: e en t . ~, , W.~' '"'"~ ;~, ^,,'i:ij~ "^,,,,,' ..c' ,.-~_L<'~' -.";,;,,:. c""':, 0<0_-"- TERRY W. TINGLE and GERALDINE K. TINGLE, : IN mE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA . . Plaintiffs : NO. 01-3758 Civil Term v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, : . . Defendant : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND mINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Megan Hook intends to serve subpoenas identical to the ones that are 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 subpoenas. If no objection is made the subpoenas may be served. Date: 4 ~)T{-o l J. Mic al ki, squire CALDWELL & KEARNS Attorney I.D. No. 87135 3631 North Front Street Harrisburg, P A 1711 0 (717) 232-7661 Attorney for Defendant Megan Hook ~ :t,,,, , ' ;~:;t,',..., .... c."'" Ie - ,. \~,,.c;.' .i"; . ~- ',-~~~ . . , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA TERRY W. TINGLE and GERALDINE K. TINGLE Plaintiffs No. 01-3758 v. CIVIL ACTION - LAW IN TRESPASS MEGAN HOOK, Defendant JURY TRIAL DEMANDED WAIVER OF TWENTY-DAY WAITING PERIOD I hereby acknowledge: (1) that I have received Defendant, Megan Hook's, Notice of Intent to Serve Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 directed to: (i) Mechanicsburg Family Practice; (ii) Orthopedic Institute of P A; (iii) Health South Rehab; (iv) KDV Orthopaedics; (v) Magnetic Imaging Center; (vi) Keystone Spine Center; (vii) The Hetrick Center; (viii) Alternative Physical Therapy; (ix) Tian Shi Acupuncture; (x) Coder Chiropractic; (xi) Tristan Associates; (xii) Neurological Surgery Ltd.; (xiii) Wharton Wellness Center; (xiv) Harrisburg Hospital; and (xv) Acorn Health Associates, P.c., in the above-captioned matter; (2) that I hereby waive the twenty (20) day waiting period for each of those subpoenas as required by the above-referenced rule; and (3) that I permit Defendant's counsel, Ray J. Michalowski, Esq., to serve each of the subpoenas immedi Date: 03' /Z9/o1 1 By: Attorneys for Plaintiffs, Terry W. Tingle and Geraldine K. Tingle 69314.1 .. " - ",," ":1" , '''-;..i,..,.' ~',"'. ,-" ,'" " ;'1,; :.1- ,~ "-,,, .." "c'-. '~..,o .&-,'~ '<~~ '~'~1f TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYL VANIA : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mechanicsburg Family Practice, 122 South Filbert Street, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to/ produce the following documents or things: Complete medical me of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PAI71lO. 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 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: Rav J. Michalowski. ESQuire Address: 3631 North Front Street Harrisburg. FA 17110 Telephone: (717) 232-7661 Supreme Court lD # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy ,.'" _Ie -".~.:..- '''-''' .' , ,,_-,,',,1,- ; ,,,,.~:;> ~, _ ., ;",,_", .'0 '~.-:" - '(~ TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute ofPA, 875 Poplar Church Road, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to/ produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. P A17110. 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 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: Rav J. Michalowski. Esquire Address: 3631 North Front Street Harrisburl!. P A 17110 Telephone: (717) 232-7661 Supreme Court 10 # 87135 Attorney for: Defendant Mel!an Hook By the Court: Date: Seal of the Court Prothonotary Deputy -~~~ - -~. - -" ~', d",'" , ~. ' ," ~'~ , '"'0'" - ;;"J:,"_".l'i",_~ill..",,,' "~-..4,;'~;,...o(-~';~'j: ..;.;,~.~; ';';; '; , : ,. TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Health South Rehab, P. O. Box 2016, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to/ produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburl!. PA17110. 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 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: Rav J. Michalowski. ESQuire Address: 3631 North Front Street Harrisburl!. PA 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal ofthe Court Prothonotary Deputy _ roo ~- .1____ ';"." - ,,'.;;~-_ ~" ","-<0"> c-'E,;k,',,;'~<,.,-,^<,,","'<:-<"~ ,',;_,-.,;-J},'>,.;.'p;:,,; "~,,' lf~'i TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term . v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: KDV Orthopaedics, 908 South George Street, York, P A 17403 Within twenty (20) days after service of this subpoena, you are ordered by the court to/ produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PA17110. 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 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: Rav J. Michalowski. ESQuire Address: 3631 North Front Street Harrisburg. P A 17110 Telephone: (717)232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THTNGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Magnetic Imaging Center, 4665 Trindle Road, Mechanicsburg, P A 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburl!. PAI7110. 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 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: Rav J. Michalowski. ESQuire Address: 3631 North Front Street HarrisburV;. PA 17110 Telephone: (717) 232-7661 Supreme Court lD # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy .. '~,., . -' ,. ," -- .- --; .~,-,j,".'",,~ .,,',%,;:.I~ --), 'i",,:~<),;~,j,~=:.~,:. .",''...., '.C,,:.. r._ ".cci' TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Keystone Spine Center, 1521 Cedar Cliff Drive, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PA17110. You may deliver or mail Jegible 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 this subpoena may seek a court order compelling you to comply with it. TIllS Subpoena was issued at the request of the following person: Name: Rav J. Michalowski. Esauire Address: 3631 North Front Street Harrisburg. PA 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy ~" '_ ". ':"",.'J,'~", J-, ,. '"",:""'~'":'"",-+,,,,-1;:,", "2;',,.., c,;~,'" _;,.~"j,j~' ,""~,"- ,.. "'~, ""'~;;"~c"."..",,t~'-;\ ilili: TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term : v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: The Hetrick Center, 500 North Union Street, Middletown, P A 17057 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PAI7110. 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 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: Rav J. Michalowski. Esouire Address: 3631 North Front Street Harrisburg. P A 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy ".'.:d,' .;-11:... 0'. _ ,',:,,~~.i;,.; .'_,;,o.,".b, -',~~ -,-.';V. .,.....?-',"'_.";;"..- . .j\;;;~ TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYL VANIA : NO. 01-3758 Civil Term v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Alternative Physical Therapy, 6510 Union Deposit Road, Harrisburg, P A 17111 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PA17110. 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 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: Rav J. Michalowski. Esquire Address: 3631 North Front Street Harrisbunz. PA 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN mE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-3758 Civil Term v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Tian Shi Acupuncture, 2315 Patton Road, Harrisburg, PA 17112 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PA17110. 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 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: Rav J. Michalowski. Esquire Address: 3631 North Front Street Harrisburg. PA 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy ~, 0 j',: _,: ,__ :... -1 ~ ,.i"'".-.'~-~I~>-, ,;,,{..( ; 'd;~' ;.,_,;_,/. <' TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Coder Chiropractic, 1624B Lincoln Highway, Lancaster, P A 17602 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical me of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PA17110. 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 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: Rav J. Michalowski. Esauire Address: 3631 North Front Street Harrisburg. P A 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy - ;, Co' ".,j" "'",-,,-<, -',",,' _,..,,:,>;~J,,,,,,," ;1,,;,]," :~,' "-";..~,'.;."",, ",;(;,<,",^x"."-z",~",,-" 0"' :i',''-''';,,~ ~~ <&t~, TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYL VANIA : NO. 01-3758 Civil Term v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Tristan Associates, 4518 Union Deposit Road, Harrisburg, P A 17111 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisbuflz. PA1711O. 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 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: Rav J. Michalowski. Esquire Address: 3631 North Front Street Harrisburl!:. P A 17110 Telephone: (717) 232-7661 Supreme Court lD # 87135 Attorney for: Defendant Mel!:an Hook By the Court: Date: Seal of the Court Prothonotary Deputy ~ .'- ,. _.C..,,'. .-......" ,,..~.J.;~ ~" ' ..-' i - ,;;; .'.,"",,, -.;;' ,,!, _~ ,,,",",~>!;,",O ,.. .l' ; '" -- . --",~~ TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term v. : CML ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Neurological Surgery Ltd., 920 Century Drive, Mechanicsburg, P A 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburl!. P A17110. 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 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: Rav J. Michalowski, Esquire Address: 3631 North Front Street Harrisburl;!. P A 17110 Telephone: (717) 232-7661 Supreme Court ill # 87135 Attorney for: Defendant Mel!an Hook By the Court: Date: Seal of the Court Prothonotary Deputy ","'-,b",," TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,.PENNSYLV ANIA : NO. 01-3758 Civil Term : v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Wharton Wellness Center, 5257 E. Simpson Ferry Road, Mechanicsburg, P A 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PA17110. 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 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: Rav 1. Michalowski. ESQuire Address: 3631 North Front Street Harrisburg. PA 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Prothonotary Seal of the Court Deputy . . "'c- , '"'. I;,:" 'T~ '-" '_.' ,.~, ~ ';,d~~; " Co', ,'~d'li' "," '7,;;. " ~,' , 'is . TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN mE COURT OF COMMON PLEAS : CUMBERLAND COUNTY~ PENNSYLVANIA : NO. 01-3758 Civil Term v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harrisburg Hospital, Cameron and MacClay Street, Harrisburg, P A 17105 Within twenty (20) days after service of this subpoena, you are ordered by the court wI produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg, P A 1711 O. 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 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: Rav J. Michalowski. Esauire Address: 3631 North Front Street HarrisbUl1!:. P A 1711 0 Telephone: (717) 232-7661 Supreme Court ill # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy . . ...,. , ~ I - -';':,:""-';',,,'>,,.,,,,,:,'- "'-'..- ,--, '-"'.<1 ""'C' Coo',}""';" "..","',,",'"":"'" 'c, '. _H-'" - ' ,- ",""=;'~~"'.h'"",;~; TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLV ANIA : NO. 01-3758 Civil Term . . v. : CIVIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Acorn Health Associates, P.c., 4701 Devonshire Road, Harrisburg, PA 17100 Within twenty (20) days after service of this subpoena, you are ordered by the court tol produce the following documents or things: Complete medical fIle of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street Harrisburl!. P A17110. You may deliver or mail legible copies of the docmnents 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 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: Rav J. Michalowski. Esauire Address: 3631 North Front Street Harrisburl!. P A 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Megan Hook By the Court: Date: Seal of the Court Prothonotary Deputy ~li;'ii;'Iim1r~'g~~m~~~~[<-w.;ii"'~m,\",,",&'''-'''';;$;+'-mi,io'$>>-::#;;''i"f~;;&j~",,","""~'~iii;{-. ~M" -'~ 'nM. -" r ';1 n r [I ,I iJ :j , 11 " Ii ~ " I' Ii ., II ~ II I 1 0 0 0 C ~fl s: rfl .-1 -0 OJ rn rh;2 mrn "0 -7::::0 I -.of'''n ~c..~ -",',0 ~4 -J ~1~~ ~6 .." C):;:2. ~8 :Jl; ~'7 "- .. ~ Ofll 5.>c -4 ~ ", ~ ...J m ~ '-'~',-~ "",,,~~,'''''"''..", ",," ."C"" ~Ch "'" <:1"<;" d '..;-:'1 ,,,-','h 'c'"',~,h;'c': ,;;. ,; ,..",~ ."" TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3758 Civil Term v. : CNlL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant Megan Hook certifies that: (1) a notice of intent to serve the subpoenas with copies ofthe subpoenas attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoenas are sought to be served; (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate; (3) no objection to the subpoenas has been received; and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoen . ) Date: C rf( f)J- ~~..- ~ ""1" ~= i',' ~ , J, .'1 ll~~_~-,', , TERRYW. TINGLE and GERALDINE K. TINGLE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO. 01-3758 Civil Term v. : CNIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Megan Hook intends to serve a subpoenas 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 no objection is made the subpoena may be served. Date: s I {Dr OJ-- ""~~,~~'- . " J-- <" < 'f" ii~""""';" , TERRY W. TINGLE and GERALDINE K. TINGLE, Plaintiffs : IN mE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV ANlA : NO. 01-3758 Civil Term v. : CIVll.. ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Cocoa Family Practice 1120 Cocoa Avenue Hershey, P A 17033 Within twenty (20) days after service of this subpoena, you are ordered by the court rot produce the following documents or things: Complete medical file of Terry W. Tingle, D.O.B. 8/22/1946, SSN 168-36-6511. At CALDWELL & KEARNS. 3631 N. Front Street Harrisburl!. PA17110. 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. Yon have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena was issued at the request of the following person: Name: Rav J. Michalowski. ESQuire Address: 3631 North Front Street Harrisburl!. P A 17110 Telephone: (717) 232-7661 Supreme Court ID # 87135 Attorney for: Defendant Mel!an Hook By the Court: Date: Seal of the Court Prothonotary Deputy ~~_~~;W:"'''i&iJHI&.~1iI''~~Mw#:'~,'Ml<M;f"~*",k:k-\~,.:,.,~,;~,,,r~''',:0''''~~i.fuj;-;it!t;;iOHB"J~L-#~fliW "'~~,-~ ~. ~ ' ~~,' ~^~, ~ ,,"<~, ,-- .- -""".l~.~ C~~', ," ~" liJOO .~ < ~ . . "~ .; ~~ " ~', , , 8 0 0 s:: N -r) "Um l:- Ii" rnf)"1 c:: ~- 2:r; ~- n1;= zC~ -0 f1l ~...?; 1'..) ~.TJO r=c'::. 06 ;< c ~ ~~:g )> ::ii: zO f )-- -,,0 70 :':-C ~ Om Z -I =< s:- ~ -< . , ~ ",~ - . ,'. ,,," ,'= ~'_"~w -" ,_' ',' ,-' ,}, '-'"~<~, ',!;, - 0- '." ,'~;c;. 'i" -"-,;..;I~::."'d ~',~~,::j:: ,~, ;~-,_, ~ ;",,> "",,J<:~~:,~:S ~~, ,~<--,; .,t~..~. if ..",.'.::../f .~ . j """"If TERRY W. TINGLE and GERALDINE K. TINGLE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : NO. 01-3758 Civil Term v. : CNIL ACTION - LAW : IN TRESPASS MEGAN HOOK, Defendant : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF SAID COURT: Kindly mark the above matter settled, satisfied and discontinued with prejudice. Respectfully submitted, LATSHA, DAVIS & YOHE, P.C. By: o than M. Crist, Es<wire upreme Court ID# ,;;{ tJ 9:J /J P. O. Box 825 Harrisburg, PA 17108-0825 Attorney for Plaintiffs Dated: "',:"Z"'~f'"" ;:; '';:'',- ",' _n',,"- I:'o'd'-, CERTIFICATE OF SERVICE AND NOW, this fi;-rflaay of J~~ '2o<J} , ~, I hereby certiJy that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Ray J. Michalowski, Esquire CALDWELL & KEARNS 3631 North Front Street Harrisburg, P A 17110 By 2 """"Y'",,, ,," .'i.1i~'.""';'.f'~.o'; "";"Iio-'J!i'm~iiMl~~'r,g~!;;!i%'>'~~~;tli"'- ilt"" ~~~ >~""'~ ,". ,- -,-=, 'iliIiUHI .;.,.""""'"'""'='~.~ ~ ~ ,", ~" " <~," ,- n~lll;l!Il~ . ~. ,_"",,",.,_r-"'l- .'""",,,' () C .- ~~~!~ -/1+ ~~r:~. :0- -'>e' ZeS PC:: -7 :=<! 'l.'!ii~" "~~ C) "" .,-:;J' ~,t; . ' 0.; .- ~) T t~f,'~. -I -" ":-c., =< -0 i:Y 1":1 U', ~