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HomeMy WebLinkAbout01-03870 <.. .. l......~ .,-,-', TAMIE AND ANTHONY STUMP, HUSBAND AND WIFE Plaintiffs v. SALLY A. LEBO, Defendant _;",,' I,:J . I'L ~,,-~ '-~,~;<. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-~1oCIVIL TERM : CIVIL ACTION - LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Write of Summons on the above named Defendant at the following address: r;!~ )01 Date Ji Sally A. Lebo 1351 Goodyear Road Gardners, PA 17324 Respectfully Submitted TURO LAW OFFICES . _ ~ ~ l' ~_~~100i<i_~tij~~~~~~~!l1':0;b;;'J0E':H(,,,i'~',;I"''',,'~Y'-'!'''::li1~''fu!i~-(hll~.nrl!iJiliit'" , "".ltiii?'l~'--lIil ~1 r~ .. .. ,:"",""',, 0_ ,_" '" ,"_~ ,'"_~" _" ~Jl'--'-~'- t' '" ~,~,.-- ~"~-~ o c:: "'1:)1~-:: !:PiX: 635~ ...---,. jg; S;: E; ~ ,..~,-- .- -~" .-....1 [J " .. .., C) C) -;" '- 1= "" (.:'3 ',j ,0,.- ,"-'f (]) 3:3 -< . .' - ,-,' , '.'J " ' "-'--,[-{.' '0;, _'_'" I ,l I" '-..".,J,,~>i, TAMIE AND ANTHONY STUMP, HUSBAND AND WIFE Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- CIVIL TERM v. SALLY A. LEBO, Defendant : CIVIL ACTION - LAW WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. /s/~ ..f Krn;} Prothonotary UC;(l9.. ;l.s. :Joo J Date ~/If~ Deputy 'I 1I , _ " ,', c<, .".,~,: . , - " -, ,~, ~- -- ," ,'- ~~~~~.lidi~1Iin!{~tlriiiWi'li'{u'.t~~'~I~J'H'\!'f""';"i!'i"-'-!I~Uu'4\ii~ji>ill".$i.' '0, ~,jOji" ...... '. -tiiJ 13 'lII'ij Ie..'''''''' "" - JLi - " ~ 0 C) 0 ~ t;:::: ~ -C ~ 'JC) '- C:oJer; ,. .~. ~ Y1 <!l ....- ~",- 00 tt ~ 1\ 'd Q~~~': (Ii -...... i~ ~v '- \.N "'"b ...-" ~ ~ '""'V CI1 ~ 4 ~ '>,-,' 7': :':;"i W ~ ~I --, -.:)1 5j -...0 :t::> -< ()"\ -< --r:-l:f ,_, Ull !Il1'!1 -,~~,~ .~ '," "," t;I; ~"" ~ I,J ._ 1,1 , , .C'. .' _'~~"'"' SHERIFF'S RETURN - REGULAR CASE NO: 2001-03870 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STUMP TAMIE ET AL VS LEBO SALLY A 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 LEBO SALLY A the DEFENDANT , at 1912:00 HOURS, on the 3rd day of July , 2001 at 1351 GOODYEAR ROAD GARDNERS, PA 17322-0004 by handing to MICHAEL LEBO, HUSBAND a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 7.15 .00 10.00 .00 35.15 So Answers: ~~~<~ R. Thomas Kline 07/06/2001 RON TURO Sworn and Subscribed to before BY~~i)dfl-- uk- Deputy She~ff me this .2?J d day of C}.?- ;).c-o! . A.D. ~Q~# V rothonotary , -. -------. ~': " I ,>,"",'),~,- ;;;f':" !:'?'~i?~ ':f"~l~ :V"{~"~~':-T~:'~':~:r~:~'I,:C!;>?;t(A;\I~~;'ti'~~l;.::~:~;r1?,r~~~:if:::-'~{'-::~~;:~~~:~~(;:i1~::~~~:fi~O"'''''':-;~:;;rt~~'?;j~: ,-, ,. .... TAMIE and ANTHONY STUMP, husband and wife, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. NO. 01-38il'>CIVIL TERM SALLY A. LEBO, CIVIL ACTION - LAW Defendant ENTRY OF APPEARANCE Please enter my appearance on behalf of Defendant, Sally A. Lebo, in the above- captioned action. Respectfully submitted, McKissock & Hoffman, P.C. BY.~~ B. Craig Black, re Attorney 1.0. No. 36818 Edwin A.D. Schwartz Attorney 1.0. No. 75902 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Date: 7- 2.~ 0 / ~,c'k ' ^ , +-"' ,.';' (< t,["~~:::~:~"':j ,~ ",' ,,,:,> ".-"~:'.":) "'?:!:WJ:~;?:?~:\~,~~"::::::;-?y; _~~,::~~',~1:~f:;~~~,t:~:r:f(~':~~:';:i~:,:,:~",j ',">''<''""!'Fii ""'::r: - .. CERTIFICATE OF SERVICE hereby certify that I am this day serving a copy of the foregoing Entry of Appearance upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 McKissock & Hoffman, P.C. BY:~ B. Craig Black, Es Supreme Court I.D. Edwin A.D. Schwartz, Esquire Supreme Court I.D. No. 75902 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Defendant, Sally A. Lebo Date: /-Z'3-t::>/ ~ Iilli~!li:liIi<'iI""':~':allf"ti'~ ";i/"':;' "'::1;:";";; ,',,':,: ";",, """",,:~"',cliI"~- ". ",',.h "'",,'., 2'"" "",~"",,,"'i,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,',h>cC,'''., " , - ..,-. l!Uil!l~, ,~,"'~C""'_"" '" _,~:C--"'."'~;>;c'(_,,7.".,,~ -' ,"'-'. ,,7 "_'>-C_'.' '" ,', ,. ~-, ", r/ .. ~-,. :,,,, -- -~-) --<; C) ....' .... '....i I I I I ~ ~ "'.>,"" . ,...."',,,'''~,' "C'.. ..":.,.."..:1'.....0. ,n;:'''>';,".... ",,'-,,-' :;":"?~ ::'.,-,j:~'<? 'Pf}1if'i!I""~'L~1'i':f[';P;~~.\"?:.~:~:':7f,i'~~'~:~~~,:'r:~,,~~r;~rf~s:',::~~'{:~' (:>:i'?~(j'__;~; .~ " TAMIE and ANTHONY STUMP, husband and wife, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. NO. 01-38il'JCIVIL TERM CIVIL ACTION - LAW SALLY A. LEBO, Defendant PRAECIPE FOR RULE TO FILE A COMPLAINT Please issue a Rule directed to Plaintiffs to file a Complaint in the above- captioned matter within twenty (20) days or suffer judgment Non Pros. Respectfully submitted, BY:~ Edwin A. D. Schwa squire RULE AND NOW, this ,:;L"I--~, day of ,),'" Lr . 2001, upon - f consideration of Defendant's Praecipe For Rule To File A Complaint, a Rule is hereby granted upon Plaintiffs to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this .:Jt:. -J.-~ day of JCA...Lf ,2001. ~J)~ ',~II:~... J. D':'J, Prothon Jy.. :; _m_.' .1 .' -' :L " ....1'11 ",,'<)!''>;''-?.;-'';i:',';,,'P';', < ,"',-- -, -"""oVrf'/;'''''- " ,-, , ,:~~ , CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Praecipe for Rule to File a Complaint upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 McKissock & Hoffman, P.C. BYEd~~~ ~. Supreme Court 1.0. No. 75902 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 Telephone: (717) 540-3400 Attorneys for Defendant Dated:7-::?3-0/ :11 Ilt.~tcr ~,. .,;"r'" 'c-!..'-"'h'ft -",~,;: - --,,~t-/l,f~::~'~ ;S:-I"I::'''I''I'I:'IL;,;' UIII ... "0""" :;-~,~~,:;:L:;;;~;;j~~':;): ,:,~,,;;;o~;,~~<,~;,,-c :_,.;" )~,~~,k~" If~W~;~ I" . ""..:-," :' "";,, '"Tl~I~!I!11~\~Lf!h~t~".~,~JAS~;r .":~ AH:c'J1UrU ,l_:~.I;kkJJJ~~ .A __c;"f,;~_"J~.,q,r,,'r,',o ,; -".-; );"~ ~< '~..0';;;,,,;~';';' ;4;''''...'",',', ;~S'; """ ""'.' " "--, """",_,,,,"",_ ""'.._~"m",, ",'7,,- . >,,," ,"",~ " ('''" "-, .~ ('" "'.' ";'il~i ~ ~ -------"'-- , " J '~~ .> ".J. -J!'j , ~"j',i'iii! " . TAMIE AND ANTHONY STUMP , HUSBAND AND WIFE Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 01- 3g7CCIVIL TERM v. SALLY A. LEBO, Defendant : CIVIL ACTION - LAW : 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 of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 :1 ! II ~,,'- ,;.. 1,1.1 '" lili~ji TAMIE AND ANTHONY STUMP , HUSBAND AND WIFE Plaintiffs v. SALLY A. LEBO, Defendant 1. 2. 3. 4. 5. 6. 7. ., I , Ii : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 01- So7tbvIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED COMPLAINT Tamie and Anthony Stump are adult individuals currently residing at 526 Baltimore Pike, Mt. Holly Springs, Cumberland County, Pennsylvania. Sally A. Lebo is an adult individual with a last known address of 1351 Goodyear Road, Gardners, Cumberland County, Pennsylvania. On or about July 9, 1999, Plaintiff, Tamie Stamp, was the owner and operator of a 1993 Dodge Shadow automobile. On or about that same date, Plaintiff, Tamie Stump, while operating said automobile was traveling south on State Route 34 and entered the intersection at State Route 34 and Pine School Road, Cumberland County, Pennsylvania. As the Plaintiff, Tamie Stump, did enter the intersection she slowed to a stop to turn left onto Pine School Road and activated her turn signal in a lawful and appropriate action. On that same said date and time, the Defendant, Sally A. Lebo, was the owner and operator of a 1994 Saturn automobile. At that same time and place, the Defendant, Sally A. Lebo, while operating the automobile referred to above, was traveling on State Route 34 at the same location as Plaintiff, immediately behind the Plaintiff as she came to the intersection referred to above. -,'.dl!:lo . ,~- II .. "'. .," . I fil~..J ,- H 8. It was the duty of the Defendant, Sally A. Lebo, to operate her motor vehicle with due care and caution in accordance with the applicable statues and ordinance at that said time and place. 9. Despite this duty of care, the Defendant, Sally A. Lebo, did impact the rear of the Plaintiff's vehicle at that same time and place, causing Plaintiff's vehicle to be shoved forward approximately 40 feet and coming to rest in the Southbound lane of State Route 34. 10. At the said time and place aforesaid, the Defendant, Sally A. Lebo, was guilty of one or more of the following careless and negligence acts or admissions: a. The said Defendant, Sally A. Lebo, did enter the intersection at an extremely high rate of speed showing reckless indifference for the safety of life and property; b. The said Defendant, Sally A. Lebo, did enter the intersection and impacted the Plaintiff's vehicle while failing to assure a clear sure sight distance ahead; c. The said Defendant, Sally A. Lebo, did operate her vehicle at the said time and place in the manner which caused her to be incapable of bringing her vehicle to a stop within the assured safe sight distance ahead, all in violation of applicable ordinances and statutes; d. The said Defendant, Sally A. Lebo, did fail to control her vehicle in such a way as to prevent her from colliding with other vehicles, specifically the vehicle being driven by the Plaintiff, Tamie Stump; e. As a direct and proximate result of one or more of the aforesaid careless and negligent acts or omissions by the Defendant, the automobile being driven by the Defendant, Sally A. Lebo, did violently collide with that vehicle being driven by Tamie Stump. ,.-<M 'I ~ II ',,1>'.1, __'0 .'" I .'~~1 COUNT ONE TAMIE STUMP v. SALLY A. LEBO 11. Paragraphs 1 through 10 are realleged and incorporated herein as if set forth in their entirety. 12. As a direct and proximate result of the aforesaid acts and omissions of the Defendant, Sally A. Lebo, the Plaintiff, Tamie Stump, suffered injuries of a pecuniary nature, including but not limited to lost wages, medical expenses, pain and suffering and physical and emotional trauma all of which are permanent. WHEREFORE, the Plaintiff, Tamie Stump, demands judgment against the Defendant, Sally A. Lebo, in a sum in excess of $1 00,000. COUNT TWO: ANTHONY STUMP v. SALLY A. LEBO 13. Paragraphs 1 through 12 above are incorporated and realleged as if set forth in their entirety. As a direct and proximate result of the aforesaid acts and omissions of the Defendant, the Plaintiff, Anthony Stump, who was the husband of the Plaintiff at the time of this accident, and continues to be the husband of the Plaintiff, Tamie Stamp, through the course of this litigation, has suffered the loss of consortium of his wife, including the loss of companionship, services, comfort, and all other associated services attributed to a spouse under applicable Pennsylvania law. 14. ti,1 ,'-'1'- "' I,~_ II I'" "' I,~I,~ ~'=~~;:~ WHEREFORE, the Plaintiff, Anthony Stump, demands judgment against the Defendant, Sally A. Lebo, in a sum in excess of $1 00,000. RESPECTFULLY SUBMITTED /o/J/ol' If !~0 Date TURO LAW OFFICES Ron Turc, Esquire 28 S. Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for the Plaintiffs ~ ' l,' ~ - .,-Lit,.;.._ -~~~ ~""~.:;,f, VERIFICA liON I, Ron Turo, Esquire, attorney for the Plaintiff herein, have sufficient knowledge of the facts contained in this Complaint and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, based upon information received from the Plaintiffs. I understand that that false statements herein made are subject to the penalties of 18 Pa. C.SA 94904 relating to unsworn falsification to authorities. loth Date It Ron Turo, Esquire TURO LAW OFFICES 28 S. Pitt St. Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs :! II ','~ , ',1'1 ~_~_1,~^ CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint upon the following individual by depositing same in United States mail, first class, postage prepaid on the A day of October, 2001, from Carlisle, Pennsylvania, addressed as follows: Edwin A. D. Schwartz McKissack & Hockman 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 TURO LAW OFFICES Ron Turo, Esquire 28 S. Pitt Street Carlisle, PA 17103 (717) 245-9688 Attorney for the Plaintiffs il ~~~~itt>~trili~~~I~t~iir~1:,~';;;;Ar;gi.'":;~:;d,:;",,,,;,~t'![;i1j-);,'1".."G,i"ld..":i,W;:;.;OO~~i'.!i.-i~Mliliifi:r"_.li.~Aj' ;r',jlJ't". "~~"~"'_ . ,O~~ "''''''-1 .~ ,~ . ,,"""_,''"'~''~~'' _h~'" , ".,,-"-. --..'~''',' ~,-~. ~,- ,,"~- -~~" -,,~,~ J.it!!i!iT --. ~gi .....- ' C/) - -" ~; >"~-~ :::j -'" (") ~.; l1.~lli.il~ilWiI[i B-:i Ii I !: r" "'r.... C.::> C) ~l , ('-,,; .~ ~-. ~ ::~) ''0 . "- , ., ' J - ~ ' ~. c--, ,-I "I.', ~, ''"'",^,,_''"' - '.-,. ,~,",~""~ TAMIE AND ANTHONY STUMP, HUSBAND AND WIFE Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3870 CIVIL TERM v. SALLY A. LEBO, Defendant : CIVIL ACTION - LAW : 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 of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 II , ~^ ".. .'. """J-..,,1.' '" ~", _' 8."k'-~';-i~'~ .... ~ TAMIE AND ANTHONY STUMP , HUSBAND AND WIFE Plaintiffs v. SALLY A. LEBO, Defendant 1. 2. 3. 4. 5. 6. 7. 8. II : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-387 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED AMENDED COMPLAINT Tamie and Anthony Stump are adult individuals currently residing at 526 Baltimore Pike, Mt. Holly Springs, Cumberland County, Pennsylvania. Sally A. Lebo is an adult individual with a last known address of 1351 Goodyear Road, Gardners, Cumberland County, Pennsylvania. On or about July 9, 1999, Plaintiff, Tamie Stamp, was the owner and operator of a 1993 Dodge Shadow automobile. On or about that same date, Plaintiff, Tamie Stump, while operating said automobile was traveling south on State Route 34 and entered the intersection at State Route 34 and Pine School Road, Cumberland County, Pennsylvania. As the Plaintiff, Tamie Stump, did enter the intersection she slowed to a stop to turn left onto Pine School Road and activated her turn signal in a lawful and appropriate action. On that same said date and time, the Defendant, Sally A. Lebo, was the owner and operator of a 1994 Saturn automobile. At that same time and place, the Defendant, Sally A. Lebo, while operating the automobile referred to above, was traveling on State Route 34 at the same location as Plaintiff, immediately behind the Plaintiff as she came to the intersection referred to above. ;:,' II - _" M' __n'- q _o,LIL,_, "-')- -,~ ~1i_;, 9. It was the duty of the Defendant, Sally A. Lebo, to operate her motor vehicle with due care and caution in accordance with the requirements of the Pennsylvania Motor Vehicle Code at that said time and place. 10. Despite this duty of care, the Defendant, Sally A. Lebo, did impact the rear of the Plaintiffs vehicle at that same time and place, causing Plaintiffs vehicle to be shoved forward approximately 40 feet and coming to rest in the Southbound lane of State Route 34. 11. At the said time and place aforesaid, the Defendant, Sally A. Lebo, was guilty of one or more of the following careless and negligence acts or admissions: a. The said Defendant, Sally A. Lebo, did enter the intersection at an extremely high rate of speed showing reckless indifference for the safety of life and property; b. The said Defendant, Sally A. Lebo, did enter the intersection and impacted the Plaintiffs vehicle while failing to assure a clear sure sight distance ahead; c. The said Defendant, Sally A. Lebo, did operate her vehicle at the said time and place in the manner which caused her to be incapable of bringing her vehicle to a stop within the assured safe sight distance ahead, all in violation of the Pennsylvania Motor Vehicle Code; d. The said Defendant, Sally A. Lebo, did fail to control her vehicle in such a way as to prevent her from colliding with other vehicles, specifically the vehicle being driven by the Plaintiff, Tamie Stump; e. As a direct and proximate result of one or more of the aforesaid careless and negligent acts or omissions by the Defendant, the automobile being driven by the Defendant, Sally A. Lebo, did violently collide with that vehicle being driven by Tamie Stump. II " " ,',. ~ -. ''1'']'__' '"~- '",.~ .., l\;:<ti.~~, COUNT ONE TAMIE STUMP v. SALLY A. LEBO 12. Paragraphs 1 through 10 are realleged and incorporated herein as if set forth in their entirety. 13. As a direct and proximate result of the aforesaid acts and omissions of the Defendant, Sally A. Lebo, the Plaintiff, Tamie Stump, suffered injuries including, but not limited to, severe back strain, trauma, bruises, lacerations, contusions, herniation, fractures all of which are of a pecuniary nature. These injuries caused the Plaintiff to be unable to work since the date of the accident and has caused the Plaintiff to suffer lost wages, medical expenses, pain and suffering and physical and emotional trauma all of which are permanent. WHEREFORE, the Plaintiff, Tamie Stump, demands judgment against the Defendant, Sally A. Lebo, in a sum in excess of $100,000. COUNT TWO: ANTHONY STUMP v. SALLY A. LEBO 14. Paragraphs 1 through 12 above are incorporated and realleged as if set forth in their entirety. 15. As a direct and proximate result of the aforesaid acts and omissions of the Defendant, the Plaintiff, Anthony Stump, who was the husband of the Plaintiff at the time of this accident, and continues to be the husband of the Plaintiff, ramie Stamp, through the course of this litigation, has suffered the loss of consortium of his wife, including the loss of companionship, services, comfort, and all other associated services attributed to a spouse under applicable Pennsylvania law. ;': , . , II -'-"0"'< 1_ _ -~ " '_ __' ':,.' O~ ;,1 ~I . "-,, > ~ '.l,: ,"'_'__ ''-'-',," WHEREFORE, the Plaintiff, Anthony Stump, demands judgment against the Defendant, Sally A. Lebo, in a sum in excess of $100,000. RESPECTFULLY SUBMITTED 1/)/01 /; Date TURD LAW OFFICES Ron Turo, Esquire 28 S. Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for the Plaintiffs ~~ - "" --0.. , :'.1 ' - ~ ',"'.,,-,' .' ",' _ _ I, ~I {_ . '--;'.'.' '~., - .w-_-_lm'';'" VERIFICA liON I, Ron Turo, Esquire, attorney for the Plaintiff herein, have sufficient knowledge of the facts contained in this Complaint and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, based upon information received from the Plaintiffs. I understand that that false statements herein made are subject to the penalties of 18 Pa. C.SA 94904 relating to unsworn falsification to authorities. It !t; Date n Turo, Esquire TURO LAW OFFICES 28 S. Pitt St. Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs Ii ""'- - -"". '~''''= 1_ -~",,-)--. '.-- .",c~,_'""--".-"~,,;,,. ,....""illh: CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint upon the following individual by depositing same in United States mail, first class, postage J Alt>t/ prepaid on the -L- day of-gelulrer, 2001, from Carlisle, Pennsylvania, addressed as follows: Edwin A. D. Schwartz McKissock & Hockman 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 TURD LAW OFFICES ~ Ron Turo, Esquire 28 S. Pitt Street Carlisle, PA 17103 (717) 245-9688 Attorney for the Plaintiffs II wi]4~~~(i'--.lI@ili~1l!l;;~"iL",.ij,~trj,ii*_\EWR'ib!~i;!:nfi5lm..<1<:M!I\!h\~-lli;tJiYiiJ-;'fh'EE,\"k1 .',1--,,..tiRl,.;';i.<hdfuiz,,-<.>i;;!@ICWl'l:1f' '.- ;.....'lii~' "lk'iil@l ;Ul.!l!IIIUlIIUmL L.L!II!!l! ~~, J ,,~ "'v"~"""',''''~' 0".- ~,.-:i< ."""".,~,.o.~ ",,~..<<_~ ~ ~ ".'0 ,_ If)!dii:i.!GB'~~JHiI~'- '~'f!i! -< ,.~ .~" ,..",., .,,~--~-,'~". o c: ';;~- -r.Jff IT; ,'ri ~~.. ~,'" ~::; '~,' 5(,', ",-L, ....-.s;:; L:" -;J -, C;::i -"_. r" " -'f"1 ~ ~:~~ -'0 :y;: '~,.) eo ! . I"~ TAMIE and ANTHONY STUMP, husband and wife, Plaintiffs v. SALLY A. LEBO, Defendant . .' r -,-,. . 'Ur' -" " . ,. ,,_<,':ch?_,~,>;'-;'-;-"- 'y.', :;-;',~--i-"'/:-' ,,',. --"";"":<~:;] -.,;,-,;,'--'j ~' - --, . .., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 0\ - 3~1-0 NO. 01-387 CIVIL TERM CIVIL ACTION - LAW ENTRY OF APPEARANCE Please enter my a"pearance as co-counsel on behalf of Defendant, Sally A. Lebo, in the above-captioned action. Date: jJ(JjI Sfc, 1..00 I ~ Respectfully submitted, McKissock & Hoffman, P.C. By: B. Crai Attorne Edwin A.D. Schwartz, Esquire Attorney 1.0. No. 75902 Craig S. Brooks, Esquire Attorney I.D. No. 62366 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 '''." ,e ""~'_, ~ ,_ , .c, .",'" -'I'",,, <<".', "J~I . ...," ->0:1. ,-.'_'f" , '''-~i%i .. '< CERTIFICATE OF SERVICE hereby certify that I am this day serving a copy of the foregoing Entry of Appearance upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, P A 17013 McKissock & Hoffman, P.C. BY t-~.flk,/ B. Craig ack, Esquire Attorney J.D. No. 36818 Edwin A.D. Schwartz, Esquire Attorney I.D. No. 75902 Craig S. Brooks, Esquire Supreme Court I.D. No. 62366 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Sally A. Lebo Date: Jb{}/I ('/ 'UJp/ i _~~ ,-~ ~.~,' "..-k,;,"~--J:--' -"'--,,,' ":g~t:< --"~~~~~~_)i~;-''',o:" l!l't",~__,<~ ,'~~,,~~~,~,~~.~"_, " WJ'.'=~ ,~". ...... ~_." ",,~',-c' - -,' -~ -,: -, ' y .. ~' ' o ~; "1Joc', f7] G:? 2"" ~S" ~-. j~ =-"j -< ~ - -.. "-' t:~) ':'.J 1'0 ~-- Ii!!iilrm.IiIi -, I I ! C) C') "';'1 .~ 23 "",::: ,"..': 1--- - -- j :' -~; "~"' , ',- I m " :2~ :.-l.d '-.J :T--' ~:J :I'J -< ~.. .', ~' . 4~" ~<. ,..' '-'"'-'~ ,,__'C~ - '" " ." ,[ .-, -~ '_,-:-,-Ln -,-,.;_':-,',,~-,,-~,,_.,_, ';0:'('''-': ""'" ~"W:,i , , TAMIE and ANTHONY STUMP, Husband and Wife, Plaintiffs v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA o J.:lnO : No.: 81 367 CIVIL TERM : CIVIL ACTION - LAW SALLY A. LEBO Defendant NOTICE TO PLEAD TO: Tamie and Anthony Stump c/o Ron Turo, Esquire Turo Law Offices 28 S. Pitt Street Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed Preliminary Objections within twenty (20) days from service hereof or judgment may be entered against you. PRELIMINARY OBJECTIONS OF DEFENDANT SALLY A. LEBO TO PLAINTIFFS' COMPLAINT AND NOW, comes Defendant, Sally A. Lebo (hereinafter referred to as "Defendant") and files the following Preliminary Objections to Plaintiffs' Complaint: 1. According to Plaintiffs' Complaint, this action arises as a result of an automobile accident which occurred on or about July 9, 1999. I. Preliminary Obiection in the Nature of Motion to Strike for Insufficient Specificity 2. Paragraph 1 of the foregoing Preliminary Objection is incorporated herein by reference as if more fully set forth herein. '," , ' I-'ijn .~. ';",,,,;,,,' - ~ .' '.l~&! \ . 3. Plaintiffs' Complaint seeks to set forth a claim of negligence against Defendant Lebo for her alleged negligent operation of a motor vehicle on July 9, 1999. Plaintiffs aver that the actions or inactions of Defendant Lebo resulted in injuries allegedly sustained by Plaintiffs, Tamie Stump and Anthony Stump, individually and as husband and wife. 4. In paragraph 8 of Plaintiffs' Complaint, Plaintiffs allege: "[i]t was the duty of the Defendant, Sally A. Lebo, to operate her motor vehicle with due care and caution in accordance with the applicable statutes and ordinances at that said time and place." (Plaintiffs' Complaint, '118 (Emphasis added)). 5. In paragraph 10 of Plaintiffs' Complaint, Plaintiffs allege: "[a]t the said time and place aforesaid, the Defendant, Sally A. Lebo, was guilty of one or more of the following careless and negligence acts or admissions: ... c. The said Defendant, Sally A. Lebo, did operate her vehicle at the said time and place in the manner which caused her to be incapable of bringing her vehicle to a stop with the assured safe sight distance ahead, all in violation of applicable ordinances and statutes; ..." 6. Furthermore, in paragraph 12 of Plaintiffs' Complaint, Plaintiffs allege: "[a]s a direct and proximate result of the aforesaid acts and omissions of the Defendant, Sally A. Lebo, the Plaintiff, Tamie Stump, suffered injuries of a pecuniary nature, including but not limited to lost wages, medical expenses, pain and suffering and physical and emotional trauma all of which are permanent." . 0, ~"'~ ;_ _,__ ,,~'^' .,j," ~,; ..,.",",;;,.IoJ,,;. . "'J-,i."',_ -,;:;:-;"',-"-":'-: c, ',_ "-:1:''-",--,,'' ~ii \ 7. The allegations referenced above do not contain the factual specificity required by Pennsylvania law, nor are they supported by factual allegations elsewhere within the Complaint. 8. Specifically, the assertions as to Plaintiff, Tamie Stump's alleged injuries are general and vague. Noticeably absent from the Plaintiffs' Complaint are any specific allegations as to the scope, nature and type of Plaintiff, Tamie Stump's alleged injuries. Furthermore, Plaintiffs' Complaint is completely devoid of any factual allegations regarding Plaintiffs' losses or impairments which are alleged to have been incurred by Plaintiff, Tamie Stump as a result of the motor vehicle accident. 9. A Complaint must not only give a defendant notice as to the nature of a plaintiff's claims and the ground upon which they rest, but it must also formulate the issues by summarizing those facts essential to support the claim. 10. Defendant objects to the Plaintiffs' Complaint as set forth herein above as being legally insufficient pursuant to Pa.R.C.P. 1019(a). 11. Courts throughout the Commonwealth of Pennsylvania have concluded that language such as set forth herein above fails to satisfy the specificity requirements of Pa.R.C.P. 1019(a). See: Connor v. Alleaheny Hospital, 501 Pa. 306, 311, 461 A.2d 600, 602-03, (1983); Hustey v. Hustey, 76 Luz. Leg. Reg. 199 (1986); Colbert v. Notarnicola, 119 Dauph. 75 (1999); Loaan v. Kemerer, 5 D.& CAth 668 (1990). ~ c. ., " 0_ "0-_ "~'^; ,: " --. /; "~- ,-",..;:-, -,_ ;1:,',1.,: , " . . ,-, -,",,,,_-,,-,_',,_~.~,,, ',n " _,,~__ ~;:':'!~ 12. Defendant is prejudiced in that Plaintiffs' failure to specifically and concisely set forth material facts and alleged injuries upon which they assert their claims precludes Defendant from preparing and effective and responsive defense thereto. WHEREFORE, Defendant respectfully request that this Honorable Court strike Plaintiffs' Complaint or, alternatively, compel Plaintiffs to file an Amended Complaint setting forth those allegations with the required specificity. Respectfully submitted: McKissock & Hoffman, P.C. By: B. Craig Black, Esqu' Supreme Court 1.0. NO.3 18 Edwin A.D. Schwartz, Esquire Supreme Court 1.0. No. 75902 Craig S. Brooks, Esquire Supreme Court 1.0. No. 62366 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 Telephone: (717) 540-3400 Attorneys for Defendant Sally A. Lebo Date: October 15, 2001 - c "~', _ - .. ~'ii; 1,,'1;;,:; ~' -".,[_,'0- ,i<,'i';:-,;,t,;,,:",,<i.-__:,'":': ~., ~:^,,;,:~~ \ CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Preliminary Objections of Sally A. Lebo to Plaintiffs' Complaint upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first- class postage prepaid, addressed as follows: Ron Turo, Esquire Turo Law Offices 28 S. Pitt Street Carlisle, PA 17013 McKissock & Hoffman, P.C. BY: -. B. Craig Black, Es Supreme Court 1.0. 6818 Edwin A.D. Schwartz, Esquire Supreme Court 1.0. No. 75902 Craig S. Brooks, Esquire Supreme Court 1.0. No. 62366 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 Telephone: (717) 540-3400 Attorneys for Defendant Sally A. Lebo Date: October 15, 2001 ~';:,jdJ..'-&i,"it:~~';"~:;'i-('idi-:"'" '""'~--",~, Ii';- ;.',:,- h~:ilif~~&~~"iiitt~l!Iillliiii't.:;;;;;c-"'-""~''''''<' I'"~ '-~'.,,"," .." ~ ',~' ',~ '-' ,''''~ , LUIllIIUII J] J I I H.l 11._.. ~~..,,~ ,.~~,. '~',,~",.~' ~,."",,,.~.". " ~" " ',- ',,~."~' < ~" .., H ~. ~,-, -I , (") 0 y C s: ;:::) :'~j "'Ott1 n ~'hJJ mr-n ..... z:c ::~~a ZC~ 0" (J)L:'; s~~ ~.L:. ~O -0 ~O ~ -0 'i' o III :;I>C --I Z ~ -' -< (J" -< , 'fd""'"'- TAMIE and ANTHONY STUMP, husband and wife, Plaintiffs v. SALLY A. LEBO, Defendant ,-. " , . ~ 1 ,',' ~,,-,"';. -, -"~'~",J' -,,-l,Is;.':':- .-;-, .'__'_H_-_ __ ',,,o!,,,_:', ,'- ,-',,"-~ '"' ,-. ~,- ,", r;;)-:'illr,1 , '1 Please enter my appearance as co-counsel on behalf of Defendant, Sally A. Lebo, in the above-captioned action. Date:04 411L dL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA O/-'bf"lO NO. 01 JIl7 CIVIL TERM CIVIL ACTION - LAW ENTRY OF APPEARANCE Respectfully SUbmitte~.,.. '; McKissoc~ & HO.~ fa. P . By: ~ /~/ 'chael B. Volk, Esquire homey 1.0. No. 88553 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 IlIT #It 1 '-1 I;,,' - '''>'-' -.-., ; .,;:,;;,"~,\;'[j".';', ",-, .'" ""'"",,,-..::-' , ";-('" _"i--'-'~"- ji:~''',,;;:''; ;,-- '" - '. -~-" c';--~2j CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Entry of Appearance upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 McKis ck & H~ BY:fVt/( / ichael B. Volk, Esquire Attorney I.D. No. 88553 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Sally A. Lebo ~ Date: t144/7(L~ ~~mi~,~d"""" "~I i~'~'Iif~(--' -li~l;;&i~~~~~d~-~' .iI:;'"' J!l!! __ ,_,~ J1!lL_ / . _,,, ,~'"!.", ~~,,-_'O"""-'_'~'''~ ..,'","',",__." _ "",. _ _~,. , . ."'" ~'n,"_ _ '. "".".';c", y~ -;. "~'.a{ _i.. . "~ "~-,,; ~. , , "" , ',',N 'N"'," "m""" _, "1. . " -~ I ~ (') C> 0 c: N -n $: :I:>o :::! v(J.::i " g;:'fT1 ;;i;;l "'-:=.:J] ;:;.J ,. .1-- zr' I ~~'Z~ w::!" (fi ^,~,.' ~I~ -."' ..2'- ~? ('~) kG " :1~--(i- ~o :K '"j" '~,(~ -0 r:? cjrn )>c: Z ..... =< N ~ C=:l -< , -, "-" "I~ j:,__; ~ ,~ ,- ;,^',,' , ~~^~ ,>"",,'i&J , TAMIE AND ANTHONY STUMP, HUSBAND AND WIFE Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-3870 CIVIL TERM v. SALLY A. LEBO, : CIVIL ACTION - LAW : JURY TRIAL DEMANDED Defendant SECOND AMENDED COMPLAINT 1. Tamie and Anthony Stump are adult individuals currently residing at 526 Baltimore Pike, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. Sally A. Lebo is an adult individual with a last known address of 1351 Goodyear Road, Gardners, Cumberland County, Pennsylvania. 3. On or about July 9, 1999, Plaintiff, Tamie Stump, was the owner and operator of a 1993 Dodge Shadow automobile. 4. On or about July 9, 1999, Plaintiff, Tamie Stump, was traveling south on State Route 34 and entered the intersection at State Route 34 and Pine School Road, Cumberland County, Pennsylvania. 5. As the Plaintiff, Tamie Stump, did enter the intersection she slowed to a stop to turn left onto Pine School Road and activated her turn signal in a lawful and appropriate action. 6. On that same said date and time, the Defendant, Sally A. Lebo, was the owner and operator of a 1994 Saturn automobile. II , ,- '~ ,", '. -J"L;-,,: _ , ",',::>- ;'" ,," ' "ii \~: 7. At that same time and place, the Defendant, Sally A. Lebo, while operating the automobile referred to above, was traveling on State Route 34 at the same location as Plaintiff, immediately behind the Plaintiff as she came to the intersection referred to above. 8. It was the duty of the Defendant, Sally A. Lebo, to operate her motor vehicle with due care and caution in accordance with the requirements of the Pennsylvania Motor Vehicle Code at that said time and place. 9. Despite this duty of care, the Defendant, Sally A. Lebo, did impact the rear of the Plaintiff's vehicle at that same time and place, causing Plaintiff's vehicle to be shoved forward approximately 40 feet and coming to rest in the Southbound lane of State Route 34. I " 10. At the aforesaid time and place, the Defendant, Sally A. Lebo, was guilty of one or more of the following careless and negligence acts or admissions: a. The said Defendant, Sally A. Lebo, did enter the intersection at an extremely high rate of speed showing reckless indifference for the safety of life and property; b. The said Defendant, Sally A. Lebo, did enter the intersection and impacted the Plaintiff's vehicle while failing to assure a clear sure sight distance ahead; c. The said Defendant, Sally A. Lebo, did operate her vehicle at the said time and place in the manner which caused her to be incapable of bringing her vehicle to a stop within the assured safe sight distance ahead, all in violation of the Pennsylvania Motor Vehicle Code; d. The said Defendant, Sally A. Lebo, did fail to control her vehicle in such a way as to prevent her from colliding with other vehicles, specifically the vehicle being driven by the Plaintiff, Tamie Stump; II l W , I. -"-. .~.'" ;_<" l ',!-, ! ~'< '_,~' '"~ " _-'"c ,_" ~"" d j'~ e. As a direct and proximate result of one or more of the aforesaid careless and negligent acts or omissions by the Defendant, the automobile being driven by the Defendant, Sally A. Lebo, did violently collide with that vehicle being driven by Tamie Stump. COUNT ONE T AMIE STUMP v. SALLY A. LEBO 11. Paragraphs 1 through 10 are realleged and incorporated herein as if set forth in their entirety. 12. As a direct and proximate result of the aforesaid acts and omissions of the Defendant, Sally A. Lebo, the Plaintiff, Tamie Stump, has suffered serious and permanent injuries including: a. Severe strain and sprain of the cervical spine; b. Severe strain and sprain of the lumbar spine; c. Severe strain and sprain of the sacral spine; d. Left leg radiculopathy; e. Sacro-i1iac joint derangement / dysfunction; f. Sacroiliitis g. h. Pelvic subluxation; Pelvic obliquity and rotation; Left piriformis syndrome; Left arm laceration; Left arm scarring; Chronic pain syndrome, (esp. pain in low back, pelvis and left leg); Depression Multiple abrasions and contusions; Post traumatic cephalalgia; Shock to the nerves and nervous system, and Mental and physical anguish. i. j. k. I. m. n. o. p. q. l! 1 A'"~ -" I, I",~~ -""-,~~^ >'F,' , 13. As a direct and proximate result of the aforesaid injuries, Plaintiff, Tamie Stump, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 14. As a further direct and proximate result of the aforesaid injuries, Plaintiff, Tamie Stump, has incurred and may continue to incur expenses for medical treatment and rehabilitation for which damages are claimed. 15. As a further direct and proximate result of the aforesaid injuries, Plaintiff, Tamie Stump, has sustained scarring and disfigurement for which damages are claimed. 16. As a further direct and proximate result of the aforesaid injuries, Plaintiff, Tamie Stump, has suffered and may continue to suffer a loss of earnings for which damages are claimed. 17. As a further direct and proximate result of the aforesaid injuries, Plaintiff, Tamie Stump, has suffered and may continue to suffer a loss of earning capacity for which damages are claimed. 18. As a further direct and proximate result of the aforesaid injuries, Plaintiff, Tamie Stump, has sustained a permanent diminution in her ability to enjoy life and life's pleasures for which damages are claimed. 19. As a further direct and proximate result of the aforesaid injuries, Plaintiff, Tamie Stump, has incurred or may hereinafter incur financial expenses and loss which exceed sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law for which damages are claimed. WHEREFORE, the Plaintiff, Tamie Stump, demands judgment against the Defendant, Sally A. Lebo, in a sum in excess of $100,000. . -. ",j -'-- -'--' -', ,';' 1'-;1";;, _ .>,,', 0:. -_c_ '" ' "~-;-_ 'j-;-- , . "" .'. '-- ---""~ , COUNT TWO: ANTHONY STUMP v. SALLY A. LEBO 20. Paragraphs 1 through 19 above are incorporated and realleged as if set forth in their entirety. 21. As a direct and proximate result of the aforesaid acts and omissions of the Defendant, Sally A. Lebo, Plaintiff, Anthony Stump, who was the husband of the Plaintiff at the time of this accident, and continues to be the husband of the Plaintiff, Tamie Stamp, through the course of this litigation, has suffered the loss of consortium of his wife, including the loss of companionship, services, comfort, and all other associated services attributed to a spouse under applicable Pennsylvania law. WHEREFORE, the Plaintiff, Anthony Stump, demands judgment against the Defendant, Sally A. Lebo, in a sum in excess of $100,000. RESPECTFULLY SUBMITTED TURO LAW OFFICES , By: Ron Turo, Esquire Carol L. Cingranelli, Esquire 28 S. Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorneys for the Plaintiffs Da1e~ /0 ,2002 I! I! -, " '...- J-_ -,,;-1,.1' _"," ,,:," ,,'. 'lIli~ VERIFICATION I, Carol L. Cingranelli, Esquire, attorney for the Plaintiffs herein, have sufficient knowledge of the facts contained in the foregoing Second Amended Complaint and verify that the statements made therein are true and correct to the best of my knowledge, based upon information received from the Plaintiffs. I understand that false statements herein made are subject to the penalties of 18 Pa. C.SA 94904 relating to unsworn falsification to authorities. #Ja; /i/ ~ Date . / Carol L. Cingranelli, Eire TURO LAW OFFICES 28 S. Pitt St. Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs Ii I ~ ,-,:1--1 ,'------, :.,,"- ':,',~-", :"., -," , -, ,-,. ' -'" "::C'f:; . CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Second Amended Complaint upon the following individual by depositing same in United States mail, first class, postage prepaid on the /t?~ay of May, 2002, from Carlisle, Pennsylvania, addressed as follows: Edwin A. D. Schwartz McKissock & Hockman 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 TURO LAW OFFICES BY: Carol L. Cingranelli, Esq Ron Turo, Esquire 28 S. Pitt Street Carlisle, PA 17103 (717) 245-9688 Attorneys for the Plaintiffs " n: ~_f&_;iltr ;,,;,.:<-K,";;iit_~~_~~~~.~.@,~lli;;j,"j.i4t,~dI_;iM;"J~;i~,~'1lIi'\1'Hi,,~~J!ll.l~~-' ,'" .< ,,;-/ . _;;;;1 ;;,:J\A~;~~ !kfJ~\I~)~;~,~t~tV".,\,J:,\,-<-;A"~~LL_,m,~-,-A,,,~ ~a!!tW}J-,;:~h'l'~' '" ,",'il',; ,':'1';;_' ",0,,' '-,_")"_0,_,,,'__ .' ~ <" ,';;v.__,,"_"'-" ,,"; "-"-o'~" '<0'" ----,"" ;~-" ..,." '" () C. ~ ~lU. ro..,j 9--..,U ~fc! S?'~': r (~:.::' ',- ! ,)_:; ,- ;<:r-", .1:;(') c:- ;;? :::? e__ _, ~, " ~~1!iisL ..:I II !j ,e;; .... ,... ~c"'" o '-' ~:,::j -" <::;, '~TjiJ} '-~'lJJ }~~. <0 ~~] .,~.() ()fl1 ::;;! 55 -.c -- .4~ ::;':' cs '. ,C"- <;::, .1;;1' ,. ="'--.-, '-., 1_:-'1_ -,..." "" ,-,-",-~ TAMIE and ANTHONY STUMP, husband and wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ()1~.3P70 NO. G'I-88? CIVIL TERM v. SALLY A. LEBO, CIVIL ACTION - LAW Defendant DEFENDANT. SALLY A. LEBO'S ANSWER AND NEW MATTER TO PLAINTIFFS' SECOND AMENDED COMPLAINT To The Within Named Plaintiffs: Tamie Stump and Anthony Stump c/o Ron Turo, Esquire 28 S. Pitt Street Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed Answer and New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. AND NOW, comes Defendant, Sally A. Lebo, (referred to as "Defendant") by and through her attorneys, McKissock & Hoffman, P.C. and submits the foregoing Answer and New Matter to the Plaintiffs' Second Amended Complaint and as such, provides the following: 1. Denied. After reasonable investigation, Defendant is without sufficient knowledge and/or information to form a belief as to the truth of the averments contained in paragraph 1 of Plaintiffs' Second Amended Complaint and as such, strict proof thereof is demanded at the time of trial. 2. Admitted. 3. Denied. After reasonable investigation, Defendant is without sufficient knowledge and/or information to form a belief as to the truth of the averments contained in paragraph 3 of Plaintiffs' Second Amended Complaint and as such, strict proof thereof is demanded at --M'<S""-,,-,1,_' ,I:, A' - ,- ~' :" - ~-- - ;,,;:~,J','-] - '__f', ,"-. --,0" :"':";";;;""""''''-'-'", OJ-, ".' ";-'o""'~:/~i the time of trial. By way of further response, it is admitted that Plaintiff, Tamie Stump, was operating a motor vehicle on or about July 9, 1999, on or about State Route 34. 4. Admitted. 5. Admitted in part, denied in part. It is admitted that on or about July 9, 1999, Plaintiff, Tamie Stump was in the southbound lane of State Route 34. The remaining averments in paragraph 5 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 6. Admitted. 7. Admitted. 8. The averments contained in paragraph 8 of Plaintiffs' Second Amended Complaint represent a conclusion of law to which no response is required. If it is later judicially determined that a response is so required, the averments contained in paragraph 8 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 9. The averments contained in paragraph 9 of Plaintiffs' Second Amended Complaint represent conclusions of law to which no response is required. By way of further response, it is admitted that on or about July 9, 1999, a vehicle being operated by Defendant, Sally A. Lebo, made contact with the rear of the vehicle occupied by Plaintiff, Tamie Stump. By way of further response, the remaining averments of paragraph 9 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 10 (a-e). The averments contained in paragraph 10 (a-e) represent conclusions of law to which no response is required. If it is later judicially determined that a ,,', " -~,y,,-- ,- ."~ :':--~.:..- ---'-'-'4'-_' '0.',,"- -_.~,- -I-'-L->~ - -':"';.':,;,;;{'i'_, _.. --~,; response is so required, the averments contained in paragraph 10 (a-e) of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. COUNT I Tamie Stump v. Sallv A. Lebo 11. The answers set forth in paragraphs 1 through 10 above, are incorporated herein as if set forth in their entirety. 12(a-q). The averments contained in paragraph 12 (a - q) of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required, If it is later judicially determined that a response is required, the averments contained in paragraph 12 (a - q) of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 13. The averments contained in paragraph 13 of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required. If it is later judicially determined that a response is required, the averments contained in paragraph 13 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 14. The averments contained in paragraph 14 of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required. If it is later judicially determined that a response is required, the averments contained in paragraph 14 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. ~ " I , , I I , , , ,"- '~'~,,-'" , -"'.cJi: 15. The averments contained in paragraph 15 of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required. If it is later judicially determined that a response is required, the averments contained in paragraph 15 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 16. The averments contained in paragraph 16 of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required. If it is later judicially determined that a response is required, the averments contained in paragraph 16 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 17. The averments contained in paragraph 17 of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required. If it is later judicially determined that a response is required, the averments contained in paragraph 17 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 18. The averments contained in paragraph 18 of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required. If it is later judicially determined that a response is required, the averments contained in paragraph 18 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. 19. The averments contained in paragraph 19 of Plaintiffs' Second Amended Complaint represents a conclusion of law to which no response is required. If it is later judicially determined that a response is required, the averments contained in paragraph 19 of , '~ ;__1-,; "'- - --, '~', -:,-11',,-'; c,b ,----,",'-,--, '-,:,:l,:;:'V,;::>'- ' , '5( Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Sally A. Lebo, respectfully requests this Honorable Court enter judgment in her favor and dismiss Plaintiffs' Second Amended Complaint with prejudice and further grant Defendant all such further relief as is proper and just. COUNT II Anthonv StumD v. Sallv A. Lebo 20. The answers set forth in paragraphs 1 through 19 above, are incorporated herein as if set forth in their entirety. 21. The averments contained in paragraph 21 of Plaintiffs' Second Amended Complaint specifically represent conclusions of law to which no response is required. If it is later judicially determined that a response so is required, the averments contained in paragraph 21 of Plaintiffs' Second Amended Complaint are specifically denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Sally A. Lebo, respectfully requests this Honorable Court enter judgment in her favor and dismiss Plaintiffs' Second Amended Complaint with prejudice and further grant Defendant all such further relief as is proper and just. ,,--y..' J,; "V'.. ,.,_J L, ~, ' j,<,- .-'..--' NEW MATTER 22. Paragraphs 1 through 21 of Defendant's Answer are incorporated herein, as if more fully set forth herein at length. 23. To the extent that facts developed during the course of discovery may implicate, Plaintiffs' claims are barred, in whole or in part, by the provisions of Pennsylvania Motor Vehicle Financial Responsibility Law. 24. To the extent that facts developed during the course of discovery may implicate, Plaintiff's injuries and/or losses, if any, were caused by persons and/or events outside the control of Defendants. 25. To the extent that facts developed during the course of discovery may implicate, Plaintiff's injuries and/or losses, if any, are barred and/or limited by the provisions of the Pennsylvania Comparative Negligence Act, 42 P.C.SA ~41 02. 26. To the extent that facts developed during the course of discovery may implicate, Plaintiff was contributorily negligent and/or assumed the risk of injury. 27. To the extent that facts developed during the course of discovery may implicate, the negligent acts and/or omissions of other individuals or entities constitute an intervening and/or superseding cause of the injuries alleged to have been sustained by the Plaintiff. 28. To the extent that facts developed during the course of discovery may implicate, Plaintiff's alleged injuries and/or losses, if any, were caused by the acts and/or omissions of a person or persons other than the Defendant in this matter. 29. To the extent that facts developed during the course of discovery may implicate, Plaintiff may have already entered into a Release and/or discharge with other individuals or entities, which has the effect of discharging any liability of the Defendant. - ~< " -,- ,,-- ..'-,/' ;" __10 1 - ~, ".', ^ '~ "";"j -iid 30. To the extent that facts developed during the course of discovery may implicate, Plaintiffs claims may be barred by the Statute of Limitations. 31. To the extent that facts developed during the course of discovery may implicate, Plaintiff's claims may be barred and/or limited by any of the affirmative defenses afforded to Defendant, pursuant to Pennsylvania Rules of Civil Procedure 1030, and as such, Defendant asserts such affirmative defenses in order to preserve such defenses to the extent that future discovery may implicate. 32. Plaintiff's injuries and/or losses, if any, are insufficient as a matter of law to constitute a "seriOUS injury" as defined by 91702 of the Pennsylvania Motor Vehicle Financial Responsibility Law. Plaintiff is therefore barred from any recovery of non-economic losses. Date: Z / ~ trZ.- By: ',- Respectfully submitted, McKissock & Hoff a ,P.. . Craig Black, Esquire .D. #: 36818 Edwin A.D. Schwartz I.D. #: 75902 Michael B. Volk, Esquire 1.0. #: 88553 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Defendant, Sally A. Lebo "^ , " -_, j - , _ "j;, - ~ 'C ,on". :"""", ,'5-- ,~',J ;L"~~N___;" '~w,'" n' -~" ',- ;, 'H' r'i:~:','l'_~: :-,-.+~ VERIFICATION I, Sally A. Lebo, hereby verify that the statements in the Answer and New Matter are true and correct to the best of my information, knowledge and belief. I understand that the statements are made subject to the penalties of PA.C.S. Section 4904, relating to the unsworn falsification to authorities. Dated: ~ 19 aoo,;. Jn~ O~ Sally A. Le . . .' t. I II.," ~, ,~ -'<~ ~""'" , . CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Answer and New Matter upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 Date: "Z- I fIVVA-J ~ 711""'" PC BY:~~ ( B. Craig Black, Esquire \.D. #: 36818 Edwin A.D. Schwartz, Esquire I.D. #: 75902 Michael B. Volk, Esquire I.D. #: 88553 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Defendant, Sally A. Lebo ~"f;'<:';'1Y';'~-::"li'\'-~~;~;;-,":-1j':,i,:-;'t;:;i;~"~";;:~,:,'>- -;Jfi'~~.~~~]j_::l.:;- :',.~~"C ~U_""'" "",",~~,'",,~....,~rr".. ~~. e"~.,,, ,",l~_.", ,,'"' ~""..o, ~";~""",,,.,, " '__, '.".". ,'~_,._;A'c" '~',' " ~''''r"" . ,'~ ___ "-'d-e' ',,~ , '" ,,-,' - ~ ".", --' -, 'd;_~ '-',_, '. ,~,_,~" -,,,,',' ::< -..4 / -, -,~ - ,-~--,-",,<< ..." .,...:.... . . r' G f T, ~ \; I. ~ t I I I i ~:- ) :----") ~-~: ,-,1 ~ '.-.:: ..;'T! :-',) 1"-'::" ~ in "::J 1"-,.) ", t..J -.-' r, .}i '-, ~ .-J ~=_~ ~ ~, ,,,~ -,'. ~i__" A "~_,, " .-, ",-,,,'I.,,] " " ,<"',,~ ,- il1;; CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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: 06/18/2002 ~ha~ B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340178 9S439-LOl , '" > '. "'~ ,- <-- - ,-,. > , ""-' ~-cl:, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF IN'l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Hote: see enclosed list of locations ] TO: CAROL L. CIHGRANELLI, ESQ. KeS on behalf of B. CRAIG BLACK, 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 KeS or by contacting our local MCS office. DATE: OS/29/2002 KeS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEFEHDAH'l' CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact TIlE KeS GROUP INC. 1601 MAll.KET STll.EET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 95439 - C 0:1 ) , ~-~ >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS Ii BILLING OTHER MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii HOSPITAL BILL MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING " . ''''-'L-'''_ '_. "" ~~ - 'l!/!l!JlI'l!',k" PAGE: 1 LOCATION NAME ROHRER BUS COMPANY K-MART ROSS WAREHOUSE H Ii R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PBAIlHACY, INC. ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CEIITEll. BLUE MT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL IIEllll.OLOGY CENTER MILTON S. BEllSBEY MEDICAL CTll.. ORTHOPAEDIC SURGERY OF RDUAIlDO s. VIOLAGO, M.D. AESTHETIC Ii RECONSTRUCTIVE SUR DE02-188480 9543 9 - C 0 1. - I, ,~. " c '_~ ." ,,~~_. "~--,'''. "~, --,-- '--"f"~ . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP AIKIA TAMIE LEA MILLER VS FileNo. 01-387D LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ROHRER BUS SERVICES (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ~J;'li' A'T''T'ArltJ;'n at MCS GROUP INC., 1601 MARKET ST, #800, PHILA.PA 19103 (Add....) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of campliance, ta the party making this request at the address listed abave. Yau have the right ta seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents ar 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: B.CRAIG BLACK, ESQ, ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 'i-246-0'lOO SUPREME COURT ID #: ATTORNEY FOR: DF.FFNnAN1' BY THE COURT: DATE: ~ ,;7,;) ;;;?&:1-2 Proth Deputy Seal of the Court (Eii. 7 ('ll) " ,', J,-" "" ' . '1'1 .,-"",-,..~ . -'. ~~17J.' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROHRER BUS COMPANY P.O. BOX 100 1515 STATE ROAD DUNCANON, PA 17020 RE: 95439 TAMIE LE STUMP AlKlA TAMIE LEA Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP AlKJA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206.56.2270 Date of Birth: 03.22-1962 5U10-377056 9S 43 9 -LOl " I. ,. " ".I",j~ ,_ ~"~j,-". ',,'~-I" "" "> ':ii~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340179 9S439-L02 , 1. ~ ,.l~ A' .;"0' ~"'r.'IC~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAB'l' TO RULE 4009.21 [ Hote: see enclosed list of locations ] TO: CAROL L. CIHGRARELLI. ESQ. KeS on behalf of B. CRAIG BLACK. 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 snd 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 KeS office. DATE: OS/29/2002 MCS on behalf of B. CRAIG BLACK. ESQ. Attorney for DEFEHDAH'l' CC: B. CRAIG BLACK. ESQ. - 8350-94 Any questions regarding this matter. contact THE MC.S GROUP INC. 1601 HARKET STREET '800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-188480 95439-CO:l.. >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMEllT EMPLOYMEllT OTHER MEDICAL RECORDS &. BILLING MEDICAL RECORDS &. HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS &. BILLING OTHER MEDICAL RECORDS &. BILLING MEDICAL RECORDS &. BILLING MEDICAL RECORDS &. BILLING MEDICAL RECORDS &. HOSPITAL BILL MEDICAL RECORDS &. BILLING MEDICAL RECORDS &. BILLING MEDICAL RECORDS &. BILLIlfG MEDICAL RECORDS &. BILLIlfG MEDICAL RECORDS &. BILLING " '" ~ '" ""' .~"'-; PAGE: 1 LOCATION NAME ROHRER BUS COMPANY K-MART ROSS WAREHOUSE H &. R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE lMAGIlfG ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PIIAlIMACY, INC. ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE !iT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER KILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUAIlDO S. VIOLAGO, K.D. AESTBE'l'IC &. RECONSTRUCTIVE SUR DE02-188480 95439-CO::L ~ , ~ ' - "n"",",,, -, ,~ ,'''-'''''''' e , ^ iIlt<illil1'-;' 4 . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: K-MART (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: c::.l4'M' A'l''T'Ar'Rt:n ~ MCS GROUP INC., 1601 MARKET ST. #800, PRILA.PA 19103 (Addreos) 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 com.,ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 71 ';-74Ii-OQOO SUPREME COURT 10 #: ATTORNEY FOR: m:"F.NTlAN'1' BY THE COURT: DATE: ~/ c;Jd) j~..;J.. Pt'Othoao Deputy : ,>{ Seal of the Court . -~~ ....,~ , '-,~-:~;;;:~;;' -" ,-""..=~ ., ,~ (r::~; .., /Q7\ . ~ ," , ; ,,' =_", _ "",;I ~Io'-:~' _ ~"o", ,-. >-, '"" ,j"'~ _ ~~ ,,' .~,~_ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: K-MART 1180 WALNUT BOTIOM ROAD CARLISLE, P A 17013 RE: 95439 TAMIE LE STUMP A/K/ A TAMIE LEA ENTIRE PERSONNEL FILE Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP AlKlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377324 95439-L02. ~~ -, .b",'.-", I,~I~ jl" ~~'~"~!Iilii~~"', CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340180 95439 -L03 ," '~-L~, 1M ~~ ,j, ',. ~ '~,.,; COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE .IlOCllMEN'l'S AND THINGS FOR DISCOVERY PURSmurr TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGRARELLI. ESQ. MeS on behalf of B. CRAIG BLACK. ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made. then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning s_ to MeS or by contacting our local MCS office. DATE: 0512912002 MeS on behalf of B. CRAIG BLACK. ESQ. Attorney for DEFERDAR'I' CC: B. CRAIG BLACK. ESQ. - 8350-94 Any questions regarding this matter. contact THE MeS GROUP IlfC. 1601 MARlET STREET 1800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-188480 95439-C01 " , >>> LOCATION LIST <<< RECORDS REQUESTED "~"--". --'-, . , I~"""i PAGE. 1 LOCATION NAME EMPLOYHEN'1' EMPLOYHEN'1' EMPLOYMENT OTHER MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, HOSPITAL BILL MEDICAL, BILLING, AJlI) X-RAY(S) MEDICAL RECORDS (, BILLING OTHER MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, HOSPITAL BILL MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, BILLING ROIIRER BUS COMPANY K-HART ROSS WAREHOUSE H (, R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PIlAIlMACY, INC. ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE HT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL IlEUROLOGY CENTER MILTOH S. HERSHEY MEDICAL CTa. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC (, RECONSTRUCTIVE SUR DE02-188480 95439 - C 0 1. ''''"'' ~. ~, 1O;i{,'. 4 . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/KI A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSt; ANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ROSS WAREHOUSE (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: c:.H'H' A 'r'r A rUlO'n at MCS GROUP INC" 1601 MARKET ST, #800, PHILA.PA 19103 (Addre..) You may deliver or mail legible copies of the documents or produce things requested by this subpoena. together with the certificate of compliancel 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 copi~s 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 com,ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 ';-24fi-OQOO SUPREME COURT ID #: AITORNEYFOR: DF.~NT1ANT BY THE COURT: DATE: 'm, CJ.,;). 01&7.;;1. Deputy Seal of the Court -";'~..'"'; .~-~~~ '~~;"':$;;,;.'<t._~ -~-~ "'..' L" "',, '_ ,kd'_ , ,,,' .. ;<j,,-j EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROSS WAREHOUSE 1707 SHEARER DRIVE CARLISLE, P A 17013 RE: 95439 TAMIE LE STUMP NKI A TAMIE LEA ENTIRE PERSONNEL FILE Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP NKlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206.56.2270 Date of Birth: 03.22.1962 SUIO-377060 9S439-L03 " -, _I ---"'1",,1 ",- - ,'~~ -~-, -'J ' " - ,~_, 6- , , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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 se~ed, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-3401Bl 9S439-L04 . '- -i;] j'J ..w ~" 'I' -j , -."=' "'t- ,~~' ,"' ~,J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERt PURSUAIIT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGRANELLI, ESQ. HCS on behalf of B. CRAIG BLACK, 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 NeS or by contacting our local HCS office. DATE: OS/29/2002 HCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEP'ENDAN'1' CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact THE MOS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DEOZ-188480 95439-CO:L ,-, >>> LOCATION LIST <<< RECORDS REQUESTED EKPLOYMEIlT EKPLOYMEllT EKPLOYMENT OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS , BILLING OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING . ,~ -JL~J"" <~' . ...-, '." , a!l:lll!i~)jj![,,'-,i PAGE: 1 LOCATION NAME ROHRER BUS COMPANY K-HART ROSS 1lARElIOUSE H , R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PHARMACY, INC. ALEXAIlDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CEN'rEll. BLUE KT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER KILTON S. HERSHEY MEDICAL CrR. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC , RECONSTRUCTIVE sua DE02-188480 95439-CO:L ,,~-" ~" ~ ~ ~1r1 "",-'::r 4 . ) COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/KIA TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: H & R BLOCK (Name of Penon at Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: C::l<'l<' A'l''T'4rlll<'n at MCS GROUP INC.. 1601 MARKET ST. #800. PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21,;-nli-OQOO SUPREME COURT ID It: ATIORNEY FOR: l)F.l1l1,N1)AN1' BY THE COURT: DATE: 7101, ;;v d;Z&? .;l. Deputy : Seal of the Court ~ .-.:.:.- . _>,c'I";d ,:'-''''I'~,:. ~ -, - ;';~" -,!;.fl~ "';-,--,-"0:' -,.,...::". Ir::" "1/Q~ ; ~' ,}, ~- ;-'" J,/I , 'j - , ,-' ",-~, " ko' EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: H & RBLOCK 30 SOUTH HANOVER STREET CARLISLE, PA 17013 RE: 95439 TAMIE LE STUMP NKlA TAMIE LEA ANY AND ALL RECORDS Subject: TAMIE LE STUMP NKJA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Socilll Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377062 9S439-L04 ~ ,..,-I _...._, _L J_j,"", ' ~ - ~' - ,- - CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340182 9S439-LOS - , ,_i1 ,," ~_ < ~. ."-0,"' ~,,~ ,"'-1 - -.' -,' _", '"C.", ,_~ ",,",' ~"'~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE IXlC1JMENTS AND THINGS FOR DISCOVERY PURStJAN'r TO RULE 40IJ9.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGRAHELLI, ESQ. KCS on behalf of B. CUIG BLACK, 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 KCS or by contacting our local KCS office. DATE: 05/29/2002 KCS on behalf of B. CRAIG BLAClt, ESQ. Attorney for DEPE1IDAIIT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GROUP IHC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 95439-COl ;> '.. >>> LOCATION LIST <<< -,", ,-"" ~ -"'~~,,'-, PAGE: 1 RECORDS REQUESTED EMPLOYMEll'r EMPLOYMENT EMPLOYMENT OTHE1I. MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTHE1I. MEDICAL RECORDS & BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS (, BILLING MEDICAL RECORDS & BILLING LOCATION NAME ROHRER BUS COMPANY K-MART ROSS WAREHOUSE H (, R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES TIIREE SPRINGS FAMILY PRACTICE HOLLY PBAllMACY. INC. ALEXANDER SPRING REBAJl, INC. APPALACHIAN ORTHOPEDIC CtNrlSll BLUE MT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER MILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OP EDUARDO S. VIOLAGO, M.D. AESTHETIC (, RECONSTRUCTIVE SUR DE02-188480 95439-C01 .'" _1. ;1'''''1''-'" '" -~~.ii~; 4 . ) COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND TAMIE LE STUMP AIKIA TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: YELLOW BREECHES EMS. INC (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ~1<'1<' A 'T''T' A rUFn at MCS GROUP INC.. 1601 MARKET ST. #800. PHILA.PA 19103 (Addres.) 'You may deliver or mail legible copies of the documents or produce things requested by this subpoe~a, together with the certificate of compIiancel 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 2] 'i-24n-OQOO SUPREME COURT ID If: ATTORNEY FOR: DF.l'l',NnANT BY THE COURT: DATE: ~~ Ol,;} ::7C1'.'.;l Prothonotary/Clerk. Civil Deputy Seal of the Court 4-;-FE1_ ......~'1i -. " ',,'1 L.. --; "",,', j - ~~1i ',;""";,, EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: YELLOW BREECHES EMS, INC. 101 NOBLE BLVD. PO BOX 100 CARLISLE, PA 17013 RE: 95439 TAMIE LE STUMP AlKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP AlKlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377064 9S439-LOS ,_._ c, -0 c' I I , ';'~__7;' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340183 9 5 43 9 -LO 6 ""L ,I 1',"'0', , .,' , ~"'," - - "0_ ." ~' - '!il#'~'!' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTENT TO SERVE A SUlU'QENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURStJART TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGRANELLI, ESQ. KeS on behalf of B. CRAIG BLAClt, 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 retuming same to KeS or by contacting our local MCS office. DATE: OS/29/2002 KeS on behalf of B. CRAIG BLACK, ESQ. Attomey for DEFE1IDA1r1' CC, B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact THE KeS GROUP llfC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 9 5 4 3 9 - C O:L - < ,~ ^ " ,"" >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTIIER MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING ,__". ' =_0 _'0",' ",,'. <~' -", - O~ ':,i"i PAGE: 1 LOCATION IIAHE ROIIRER BUS COMPANY It-MART ROSS WAREHOUSE H & R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES TIIREE SPRINGS FAKILY PRACTICE HOLLY PHARMACY, INC. ALEXAllDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE NT. ANESTHESIA ASSOC. PAIN CLIllIC-CARLISLE HOSPITAL NEUROLOGY CEIlTER MILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SUllGEllY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC & RECONSTRUCTIVE SUll DE02-188480 95439-C01 . "" ~"--,'jf" ---; 4 . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS File No. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL (Name o( Penon Qr Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ~l4'H' b,'T''T'b,r1=l1<'Tl at MCS GROUP INC., 1601 MARKET ST, #800. PHILA.PA 19103 (Addres.) 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 aiter 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: B.CRAIG BLACK. ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG. PA 17110 TELEPHONE: 71 'i-24/i-OQOO SUPREME COURT lD II: A TIORNEY FOR: m:FRN1lAN'1' BY THE COURT: DATE: 'pt~ d7~. .70~ Deputy .- Seal of the Court , ,,;,;e ':"- "'~.;::;:~~ , ---;:-; .".,~...: >>t _-I ".. -,__" ~ ' " 'I. 1 ~ , , ,,,, ,,0 ~" -",-,' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL P.O. BOX 310 246 PARKER STREET CARLISLE, PA 17013 RE: 95439 TAMIE LE STUMP NKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment of patient. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP NKlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377066 9S439-L06 " ""j-j'o "'" ~.r.,-" ,I' ;" :""-'h CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340184 9543 9-LO 7 I 1-[' " ", " ~, " " ". ~,W~<-~"~ ~l:t!I:iI"'~>~,i' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSwurr TO RULE 4609.21 [ Note: see enclosed list of locations) TO: CAROL L. CINGRANELLI, ESQ. MCS on behalf of B.' CRAIG BLACK, 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: OS/29/2002 MCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEFEHDANT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact TIlE MCS GROUP INC. 1601 HAlUtE'r STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 95439-CO:L >>> LOCATION.LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BOSPITAL BILL MEDICAL, BILLING, AND X-KAyeS) MEDICAL RECORDS Ii BILLING OTHER MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING MEDICAL RECORDS Ii BILLING MEDICAL llECORDS Ii HOSPITAL BILL MEDICAL llECORDS Ii BILLING MEDICAL llECORDS Ii BILLING MEDICAL llECORDS Ii BILLING MEDICAL llECORDS & BILLING MEDICAL llECORDS & BILLING ~~, -I~.' , "~ -. ,,"'~' ik)!l:-il" PAGE: 1 LOCATION NAME ROBllER BUS COMPANY K-MART ROSS WAllEBOUSE B Ii R BLOCK YELLOW BREECHES EMS, INC. CARLISLE BOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PHARMACY, INC. ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE MT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL IlEOROLOGY CENTER MILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC Ii RECONSTRUCTIVE SUR DE02-188480 95439-COl '" - ], ^. ' , ,~, ~ _ .,~,. w ~ ".0". ~ . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CARLISLE IMAGING ASSOC. (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: C::lilf' ATTArUlin at MCS GROUP INC.. 1601 MARKET ST, #800. PHILA.PA 19103 (Add....) 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 t_his 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 'i-?4fi-O'lOO SUPREME COURT ID It: ATIORNEYFOR: DF.FF.NnANT BY THE COURT: DATE: 7>1~ Old ,:;! &;,;;l- Deputy Seal of the Court -~ .'---.~ .~,:E~ rr::u '710'7\ '-<!:'_.~,.lI: '.'" '..........~~ -,. j'j _,,-,'1-1 - - -.-~", . !;;t,e!,~", ' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE IMAGING ASSOCIATES P.O. BOX 100-101 NOBLE BLVD., STE 104 CARLISLE, PA 17013 RE: 95439 T AMIE LE STUMP NK/ A TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP NKlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377068 9S439-L07 "' ;1,-1 ," ~ ' ^'~~,,;; CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340185 95439 -LOa ., ~- " , ,"'- .,~ ','oC~__" -- " . >~~', ~o," ~~)k COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTElI1T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAWl' TO RULE 4009.21 [ Note, see enclosed list of locations ] TO, CAROL L. CINGRANELLI, ESq. KCS on behalf of B. CRAIG BLACK, BSQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is _de, then the subpoena _y be served. Complete copies of any reproduced records _y be ordered at your e%pense by completing the attached counsel card and returning same to KCS or by contacting our local KCS office. DATE: OS/29/2002 IfCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DBFBIIDA1l'f CC, B. CRAIG BLACK, ESq. - 8350-94 Any questions regarding this _tter, contact THE KCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l88480 95439-CO:l.. ~ ,,~ ,I j . >>> LOCATION LIST <<< '_"'.0 __ " -c"........, '.Ii J ~,~"'-,' -~':' PAGE: 1 RECORDS REQUESTED EMPLOYHEIIT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS , BILLING OTBEll MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL IlECORDS , BILLING LOCATION NAME ROHRER BUS COMPANY K-MART ROSS WAREHOUSE H , R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PBAIlMACY, INC. ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CEIl'fER BLUE KT. AIlESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER HILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUARDO S. VlOLAGO, H.D. AESTHETIC , IlECONSTRUCnvE SUR DE02-188480 95439-COl , -,,< W!.HL -r ' "=,1 ~ .:: . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO . SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: THREE SPRINGS FAMILY PRACTICE (Name of Penon ot Entity) Within twenty (20) days aiter service of this subpoena, you are ordered by the court to produce the following documents or things: C:lili" A"r'l'A("'J.,fli'l) at MCS GROUP INC., 1601 MARKET ST, #800, PHILA.PA 19103 (Add....) 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 \0 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, FA 17110 TELEPHONE: 21 ';-246-0QOO SUPREME COURT ID #: A TIORNEY FOR: DRFRNnA NT BY THE COURT: DATE: ~fr .;7,;; 02&/ d.. PTOthonota Deputy : Seal of the Court - .:;c""e ,,,,,,-:,"'I~- Iiiiii' '. ,ni ,;-~2,'~ ,n ,__, - - ~-"',-, ',"' ~h ' , -",",~-~.""--,, <~"""... ,,~~ ,,-(> 'V-, EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THREE SPRINGS FAMILY PRACfICE 303 N. BALTIMORE AVE. MT. HOLLY SPRINGS, PA 17065 RE: 95439 TAMIE LE STUMP NKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP NKlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56.2270 Date of Birth: 03-22-1962 8U10-377070 9 5 43 9 -L 0 8 l ~-- II 1, " '.._- , - ,-"'" , ~ - *'-.' '" CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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 servedt (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340186 95439 -L09 ,,', q - . -~ JI,-, ,,~.. '- 1 ,"~o .d l~r~. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE lX)CUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGRANELLI, ESQ. KeS on behalf of B. CRAIG BLACK, 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 KeS or by contacting our local KeS office. DATE: OS/29/2002 KeS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEFENJlAIIT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GROUP IRC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 95439-C01 - ,-- >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS , BILLING OTHEll MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING ., . ~ -,"- ,~ -, '~ll< PAGE: 1 LOCATION NAME ROHRER BUS COMPANY K-MAll.T ROSS WAREHOUSE H , R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIA'rES THREE SPRINGS FAKILY PRACTICE HOLLY PlIABMACY, INC. ALEXAlIDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC (;J<IITl!ilt BLUE KT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER MILTOH S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGEJl.Y OF EDUARDO S. VIOLAGO, H.D. AESTHETIC , IlECONSTRUC'UVE SUB. DE02-188480 95439 - C O:L ~, " J__ - - ,~ -'- ,~, .....~-,", _lilJi!k:!lllir--lif~, A . ) COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOLLY PHARMACY, INC. (Name of Penon or Entity) Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: C::P'li' A'T'TAr'R'li'n at MCS GROUP INC., 1601 MARKET ST. #800. PHILA.PA 19103 (Add....) You may deliver or maillegibJe 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 'i-24n-OllOO SUPREME COURT ID #: ATIORNE'i FOR: nEFF.NIlAN'!' BY THE COURT: DATI: 7W', <5'0l 07a:?';( Deputy Seal of the Court -,..... -"B ' "":':~:'::'..-~.;....:~ - ;:,...::'-:". . -~ I " ol~ ~,j ''"' .,I.....J ,"C,\ ~- ," "'-""'~~. EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLLY PHARMACY, INC. 31 N. BALTIMORE AVE MT. HOLLY SPRINGS, PA 17065 RE: 95439 T AMIE LE STUMP NKI A TAMIE LEA ANY & ALL RECORDS & BILLING. Subject: TAMIE LE STUMP NKJA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377072 95439-L09 . > "~ ,- -.' ,-,-' 1.';"1." "" " --,.,:'-, ""'. ' ". "'.'", CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340187 9S439-LlO ~"~ , ., li >,~"'" -<'fu:j," COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF IN'rEw.r TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note. see enclosed list of locations ] TO. CAIl.OL L. CINGllANELLI, ESQ. MCS on behalf of B. CRAIG BLAClt, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You bave 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. OS/29/2002 MCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEl'EHDAllT CC. B. CRAIG BLAClt, ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GlUlUP 11IC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 95439-CO~ +" ,-j,( ,. >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTHER MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL .RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING ..~. - 'I^~' '--\lgtd "=" -, PAGE: 1 LOCATION NAME ROHRER BUS COMPANY K-MART ROSS WAREHOUSE H & R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGIllG ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PBA1lHACY, INC. ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE KT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL 1lEUR0LOGY CENTER MILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC & RECONSTRUCTIVE SUB. DE02-188480 954-:3 9 - C 01. - ; , --------------===, 4 . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB (Name ol Penon or Entityl Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: ~l<'li' A'T''l'ArJ:{l<'n at MCS GROUP INC., 1601 MARKET ST, #800. PHILA.PA 19103 (Addre..) 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 2] 5-24/l-0ClOO SUPREME COURT 10 #: AlTORNEYFOR: DF.FF.NDANT BY THE COURT: DATE: ~fr OlcJ. 07~d Deputy Seal of the Court - --~ -~'''''..'' - , -." . ~'~O<~_~ , '" -,;;,~--:,~ ~" '!' 'I ~ , - "bJl ' ~. ' ,,-" ~,; , " hi,'.?] EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB, INC. 27 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: 95439 TAMIE LE STUMP NKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP NK./A TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 5UlO-377074 9S439-L10 - -1,1 , ',~" ' <"""'~'~'-;;',,- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340188 9S439-Lll .'~ .. . "--',," .. "", ".' - ';L"' (11 Li!M:~, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4609.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGRANELLI, ESQ. MCS on behalf of B. CRAIG BLAClt, 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: OS/29/2002 MCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEPEllDANT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GROUP IHC. 1601 MAllKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 95439-COl >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL. BILLING. AND X-RAY(S) MEDICAL RECORDS , BILLING OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLIlfG MEDICAL llECORDS , BILLING MEDICAL RECORDS , BILLING "h' -. a""",,'-"'_ PAGE: 1 LOCATION NAME ROBREll BUS COMPANY K-HART ROSS llAllEBOUSE H , R BLOCK YELLOll BREECHES EMS. IlfC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY Pa.uutACY. INC. ALEXANDER SPRING REHAB. IlfC. APPALACHIAN ORTHOPEDIC CENTER BLUE KT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER MILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO. M.D. AESTHETIC , RECONSTRUCTIVE SUR DE02-188480 95439-C01 ~-. --, "~'" . . " 4 . COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: APPALACHIAN ORTHOPEDIC CENTER (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or tt"ings: C::'Fti' A'T''1''ArUl<'n at MCS GROUP INC., 1601 MARKET ST, #800, PHILA.PA 19103 (Add"...) 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 'i-?4n-OQOO SUPREME COURT ID II: ATIORNEY FOR: DF:FF:NDAN'l' BY THE COURT: DATE: >r7,. d}o;. .;74?.;z Prothon Deputy Seal of the Court ~- ....,....-',.t;;i ~....- <<~~ ":~~~~"~ ,...~;r I'CU "1/0"r\ ~ - ,~ ,,-," ,~ "j;j<".-i '-'1 I EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: APPAlACHIAN ORTHOPEDIC CENTER 1 DUNWOODY DR. CARLISLE, PA 17013 RE: 95439 TAMIE LE STUMP AJKI A TAMIE LEA ANY AND ALL RECORDS FROM JOHN C. RODGERS, M.D. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP AlKlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377326 9S439-Lll '" ,..,J' , ,,_J " .. ".',,- -~- '/ir.,'?J-- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340189 95439-Ll2 '" j -< - ~ - ,~ .:.ll..;,l-"';=' -- .' , . ",M' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP AIKIA TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF IN'l'E1l'1' TO SERVE A SUBPOENA TO PRODUCE DOCUMEIl'1'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Hote: see enclosed list of locations ] TO: CAROL L. CINGRAllELLI, ESQ. MCS on behalf of B. CRAIG BLACK, 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: OS/29/2002 MCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEFBRDAIIT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact 'l'BE MCS GROUP DIe. 1601 MAIlKET STREET #800 PHILADELPHIA, PA 19103 (US) 246-0900 DE02-188480 95439-COl >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-KAYeS) MEDICAL RECORDS & BILLING OTHER MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING .. ,,=- ~>" . -"'", PAGE: 1 LOCATION NAME ROHRER BUS COMPANY X-MART ROSS WAREHOUSE H & R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES TIIREE SPRINGS PAHILY PRACTICE HOLLY PHARMACY, INC. ALEXAIlDEll SPRING REHAB, IHC. APPALACHIAN ORTHOPEDIC CEIITE1l. BLUE KT. ANESTHESIA ASSOC. PAIN CLUIIC-CARLISLE HOSPITAL NEUIl.OLOGY CEIITE1l. KILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SUBGEllY OP EDUAllDO S. VIOLAGO, M.D. AESTHETIC & RECONSTRUCTIVE SUR DE02-188480 95439 - C 0:1. J . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: BLUE MOUNTAIN ANESTHESIA ASSOC. (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ~l<'H' A'1''T'ArUl<'n at MCS GROUP INC.. 1601 MARKET ST. #800. FHILA.FA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to com,ply with it. EllS SUBPCENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B.CRAIG BLACK. ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG. FA 17110 TELEPHONE: 21 ~-24Ii-OQOO SUPREME COURT ID If: AlTORNEY FOR: nF.F~NTJAN1' BY THE COURT: DATE: )?1,. OQ 02tZJ d. PTOthonota Deputy Seal of the Court , '" ~:i,:~~. '"'":-:~-. ->_.t. '-~:- . , '. J__ I_J. ,', -'>~ ';.'"' ':'~ ~~ -'- $i.., EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BLUE MT. ANESTHESIA ASSOC. P. O. BOX 249 GREENCASTLE, PA 172250249 RE: 95439 TAMIE LE STUMP NKJA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP NK/A TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377078 95439-L12 . , ,,' "-';'1- -~,) CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340190 9S439-Ll3 ~' '~~"'bl<;' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OP IN'.rENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS POR DISCOVERY PURSUANT TO RULE 40!09.2l [ Note. see enclosed list of locations ] TO. CAROL L. CIBGRAIlELLI, ESQ. HCS on behalf of B. CRAIG BLACK, 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 s_ to KeS or by contacting our local KeS office. DATE. OS/29/2002 KeS on behalf of B. CRAIG BLACIt. ESQ. Attorney for DEPEBDAB'f CC. B. CRAIG BLACK. ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-188480 954:3 9 - C O:L >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS & BILLING MEDICAL llECORDS , BILLING MEDICAL llECORDS , HOSPITAL BILL MEDICAL RECORDS , BILLING MEDICAL llECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL llECORDS , BILLING MEDICAL llECORDS , BILLING "'~'- PAGE, 1 LOCATION NAME ROHRER BUS COMPANY K-MAIlT ROSS WAREHOUSE H , R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PHARMACY, INC. ALEXANDER SPRING 1lEBAIl, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE MT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER MILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC , llECONSTRUCTIVE SUR DE02-18B480 95439-CO:1.. .-" ~ . ) COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND TAMIE LE STUMP AIKIA TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PAIN CLINIC-CARLISLE HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: C:l4'li' A"r"rAf''R'li'Tl at MCS GROUP INC., 1601 MARKET ST. #800, PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things requi1ed 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, FA 17110 TELEPHONE: 21 'i-?4n-OQOO SUPREME COURT ID It: ATTORNEY FOR: DF.FF.N11ANT BY THE COURT: DATE: ~~ c!7Cl, .;7<0'..7 Deputy Seal of the Court ;:l~ ~ "'-',,,:,,:~ "",," "' - ~ " >>,L=I' ~ :.; -," ~ - ' I!>'L"J EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PAlN CLINIC-CARLISLE HOSPITAL 246 P ARKET STREET CARLISLE, PA 17013 RE: 95439 TAMIE LE STUMP A/KlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment of patient. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP A/KlA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377328 95439-L13 ,~ "' > 4'j '~,-'- ~" '" l!i~m, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/1812002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340191 9543 9-L14 , ~~ ~ ~~- ~ ""'fl- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURStIAN'r TO RULE 4009.21 [ Note: see enclosed list of locations ] TO, CAll.OL L. CINGllANELLI. ESQ. MCS on behalf of B. CRAIG BLACX. ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made. then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: OS/29/2002 MCS on behalf of B. CRAIG BLACK. ESQ. Attorney for DEFENDAN'l' CC: B. CRAIG BLACK. ESQ. - 8350-94 Any questions regarding this matter. contact 'rIlE MCS GROUP INC. 1601 MARKET STREET '800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-188480 95439-COl - --, , >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYHEllT EMPLOYHEllT EMPLOYMENT O'l'llER MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL, BILLING, AND X-KAyeS) MEDICAL RECORDS' BILLING OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING '- ~-- -~ ~ia''''~" PAGE: 1 LOCATION NAME ROIlRE1l BUS COMPANY K-HART ROSS WAREHOUSE H , R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PllACTICE HOLLY PHARMACY, INC. ALEXAND~ SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE K'1'. AIlES'l'IIESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL IlEUROLOGY CENTER MILTON S. BERSBEY MEDICAL C'l'R. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO. M.D. AESTHETIC , RECONS'l'RUCTIVE SUR DE02-188480 95439-COl ,-I . I "",- ~ ~ -. . ~'...."",,,,- 4 I . , - , I ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP AIKIA TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: NEUROLOGY CENTER (Na.me of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: C:li'li' A''T'''T'ArRli'n at MCS GROUP INC., 1601 MARKET ST, #800, PHILA.PA 19103 (Address) You may deliver or mailtegible 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 rail 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: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21,-?4/i-OQOO SUPREME COURT In #: A TIORNEY FOR: DF.l'F.NT1AN1' BY THE COURT: DATE: ~~ C}.;J 07&Y.?Z Deputy Seal of the Court -- ,-_I ;,~:";'m-~ ""'-:~"'-!'!--'" '~" J flJ ,'" ,-'"-, I ,I--J , ;,0 . ,_"~,,, , "" ,~, EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NEUROLOGY CENTER 897 POPlAR CHURCH ROAD CARLISLE, PA 17011 RE: 95439 TAMIE LE STUMP A/K/A TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP NKJA TAMIE LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206.56.2270 Date of Birth: 03-22-1962 5UIO-377082 95439 -L14 . " I'J ."~-~" '~ ~>--~ '1.~$__ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340192 95439-L~5 ,--]. ,<"""~''-'L~'''Mid COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE J:lOClJMEftS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGllAHELLI, ESQ. KCS on behalf of B. CRAIG BLACI:, 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 ezpense by completing the attached counsel card and retuming same to MCS or by contacting our local KCS office. DATE: 05/29/2002 MCS on behalf of B. CBAlG BLACK, ESQ. Attorney for DEFE1lDAII'1' CC: B. CRAIG BLACI:, ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GB.OUP DlC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 9 5 4 3 9 - C 0 1. ,. >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS" BILLING MEDICAL RECORDS " HOSPITAL BILL MEDICAL, BILLING, AND X-RAyeS) MEDICAL RECORDS " BILLING OTBEJl. MEDICAL RECORDS " BILLING MEDICAL RECORDS " BILLING MEDICAL RECORDS " BILLING MEDICAL RECORDS " HOSPITAL BILL MEDICAL RECORDS " BILLING MEDICAL RECORDS" BILLING MEDICAL RECORDS " BILLING MEDICAL RECORDS " BILLING MEDICAL RECORDS " BILLING -." '"", - - ~,< , LiIJ.~'" <",He ~ PAGE: 1 LOCATION NAME ROBREll BUS COMPAIIY K-KAIlT ROSS WAREHOUSE B " R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE BOLLY PHARMACY, INC. ALEXANDER. SPRING REHAB. INC. APPALACHIAN ORTHOPEDIC CENTEll. BLUE !iT. ANESTHESIA ASSOC. PAIN CLDllC-CARLISLE BOSPl'rAL IlEUROLOGY CENTEll. MILTOR S. BEJl.SBEY MEDICAL eTll. ORTHOPAEDIC SUEGER.Y OF EDUARDO S. VIOLAGO, M.D. AESTHETIC " RECONSTIlUCTIVE SUE DE02-188480 9543 9 - C O:L ,ij ",,1~'J. _ -", ,-- "~li:r,; 4 . ) COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL CENTER (Name or Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ~l<'l<' A'T''T'A(''RlO'T\ at MCS GROUP INC.. 1601 MARKET ST. #800. PHILA.PA 19103 (Ad<lre..) You may deliver or mailtegible 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 com_ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 ~-?46-0qOO SUPREME COURT 10 It: ATrORNEY FOR: m',VVNnAN'1' BY THE COURT: DATE: ~, 42, O!~~ Prothono Oeputy Seal of the Court ~.>.,~. ,,~C," ""'-'. -'-' '^ '~i ~~ . , ,;,.~ -~ ,,' I ~J "0 EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL CfR. MCHU 24 P.O. BOX 850 HERSHEY, PA 17033 RE: 95439 TAMIE LE STUMP NKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including thMiEsent. Subject: TAMIE LE STUMP A/KIA TA LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377084 95439-L15 . ,-, , - - .~ -"', '~ ,1, " :'" ~: ~ - ~~, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340193 9S439-L16 "~~'" " ' .. :![: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP AIKIA TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE PQCUMEN'l'S AND THINGS FOR DISCOVERY PURS1JAN'1' TO RULE 4009.21 [ Hote: see enclosed list of locations ] TO: CAROL L. CIHGRAHELLI, ESQ. KeS on behalf of B. CRAIG BLACI:, 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 _de, then the subpoena _y be served. Complete copies of any reproduced records _y be ordered at your expense by completing the attached counsel card and returning su. to KeS or by contacting our local KCS office. DATE: OS/29/2002 KeS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEFENDANT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this _tter, contact THE KeS GROUP IRC. 1601 HARKET STREET #800 PIlIUdlELl'BlA, PA 19103 (215) 246-0900 DE02-188480 95439 - C 0:1. >>> LOCATION LIST <<< RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS r. BILLING MEDICAL' RECORDS r. HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS r. BILLING OTHER MEDICAL RECORDS r. BILLING MEDICAL RECORDS r. BILLING MEDICAL RECORDS r. BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS r. BlLLlllG MEDICAL RECORDS & BILLING _-"'c_ PAGE: 1 LOCATION NAME ROIIRER BUS COMPANY It-HART ROSS WAREHOUSE H r. R BLOCK YELLOW BREECHES EMS. INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PIIAllHACY, INC. ALEXAJlDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CEN'l'ER BLUE HT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL lIElIROLOGY CENTER KILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC & RECONSTRUCTIVE SUR DE02-188480 9543 9-CO~ "" ~~ ." " .o~ ,_ ~"~, ,"""",,~,, . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC SURGERY OF CARLISLE, LTD (Name of Person or Entity) Within twenty (20) days aiter service of this subpoena, you are ordered by the court to produce the following documents or things: ~""lO' 4 '1"" A (""R"J,'T) at MCS GROUP INC.. 1601 MARKET ST, #800. PHILA.PA 19103 (Add....) 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 aHhe 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 raU to produce the documents or things required by this subpoena, within twenty (20) days aiter its service, the party serving this subpoena may seek a court order compelling you to com,ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 'i-74n-OQOO SUPREME COURT ID It: ATTORNEY FOR: DF.FF.NTlAN'T' BY THE COURT: DATE: ~, cPdl., d&l~ Prothol1 Deputy Seal of the Court ;,~:X-~ ~,r-'~!~!lV' - -~ :~._::::5 " ~" '1,1- , L, "", $ ~. "~, EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC SURGERY OF CARLISLE, LTD 816 BELVEDERE STREET CARLISLE, PA 17013 RE: 95439 TAMIE LE STUMP AlKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMIE LE STUMP A/KlA TAMIE LEA Mll.LER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377086 95439-L~6 ,,' k,j ,~" " " ",.", c, , ,~-, , ,,-;;,. ,&', CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK, 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340194 95439-L17 ll"". "'" , -Jl.,1'- ',c.. . .---:, ,-,~~, I' , ~~- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'l'S AND THINGS FOR DISCOVERY PURSUAN'rTO RULE 4009.21 [ Bote: see enclosed list of locations } TO: CAROL L. CIBGRANELLI, ESQ. MCS on behalf of B. CRAIG BLACK, 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 erpense by completing the attached counsel card and returning s_ to MCS or by contacting our local MCS office. DATE: OS/29/2002 MCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEFE1lDAIIT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GROUP me. 1601 MARKET STllEET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-188480 95439-COl ,_ :.d ," '''-I ,-, " , j! I:lll!.U,,-,o >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL, BILLING, AND X-RAyeS) MEDICAL RECORDS , BILLING OTHER MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , HOSPITAL BILL MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING MEDICAL RECORDS , BILLING LOCATION NAME ROIlREll. BUS COMPANY K-HART ROSS WAllEBOUSE H , R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PHAllHACY, INC. ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER BLUE MT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER HILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SURGERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC , RECONSTRUCTIVE SUR D802-188480 95439-C01. - '" , "~"O ~ . ) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS File No. 01-3870 LEBO SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ED VIOLAGO, M.D. (Name of Penon or Entity) Within twenty (20) days after service ot this 5ubpoena~ you are ordered by the court to produce the following d.ocuments or things: ~1+'14' A'l"T',1 r'R'1+'n at MCS GROUP INC., 1601 MARKET ST, #800, PHILA.Pk 19103 (Add..,,) 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 \':/.5 ISSUID AT THE REQU;::3T OF rfiE FOLLO,m\jG PERS01'i, NAME: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA 17110 TELEPHONE: 21 'i-24fi-OQOO SUPREME COURT ID #: AITORNEYFOR: DF.FF.1Il11AN'l' BY THE COURT: DATE: ~ ,;ea. .;la9dl Deputy Seal of the Court ?;;',~~ ;', -,~~ '. < ,~.,., ". --'"'- . , I j- ~"-_ - ~- , "" 'i;.'~"_ EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EDUARDO S. VIOLAGO, M.D. 2151 LINGLESTOWN RD. HARRISBURG, PA 17110 RE: 95439 TAMIE LE STUMP AlKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMffi LE STUMP A/KlA TAMm LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 5UIO-377088 95439-L17 L.-' .Ifl ~ ~ ,,~-' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of B. CRAIG BLACK. 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. MCS on behalf of DATE: 06/18/2002 B. CRAIG BLACK, ESQ. Attorney for DEFENDANT DEll-340l95 95439 -L1B -, - >-,I'J .~,L- ,,"N' 'i_ , ......,,-',;' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS TAMIE LE STUMP A/K/A TAMIE LEA MILLER TERM, -VS- CASE NO: 01-3870 LEBO NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: CAROL L. CINGRANELLI. ESQ. MCS on behalf of B. CRAIG BLACK. 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: OS/29/2002 MCS on behalf of B. CRAIG BLACK, ESQ. Attorney for DEFENDANT CC: B. CRAIG BLACK, ESQ. - 8350-94 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-l88480 95439-COl >>> LOCATION LIST <<< ,""-' '""' .--, ." ~ii.-_ PAGE: 1 RECORDS REQUESTED EMPLOYMENT EMPLOYMENT EMPLOYMENT OTHER MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING OTHER MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & HOSPITAL BILL MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING LOCATION NAME ROHRER BUS COMPANY K-MART ROSS WAREHOUSE H & R BLOCK YELLOW BREECHES EMS, INC. CARLISLE HOSPITAL CARLISLE IMAGING ASSOCIATES THREE SPRINGS FAMILY PRACTICE HOLLY PHARMACY, INC. ALEXANDER SPRING REHAB, lNC. APPALACHIAN ORTHOPEDIC CENTER BLUE MT. ANESTHESIA ASSOC. PAIN CLINIC-CARLISLE HOSPITAL NEUROLOGY CENTER MILTON S. HERSHEY MEDICAL CTR. ORTHOPAEDIC SUll.GERY OF EDUARDO S. VIOLAGO, M.D. AESTHETIC & RECONSTRUCTIVE SUR DE02-188480 95439-CO~ - ,---. -&~- S-<;'" . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TAMIE LE STUMP A/K/A TAMIE LEA MILLER VS FileNo. 01-3870 LEBO TO: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF RECORDS FOR: AESTHETIC & RECONSTRUCTIVE SURGERY OF CENTRAL PA (Name of Penon or Entity) Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: ~"'1+' A'T''T'Af'l:(lm at MCS GROUP INC., l60l MARKET ST, #800, PHILA.PA 19103 (Add.....) 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 compelHn~ Y(ltl to com.ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B.CRAIG BLACK, ESQ. ADDRESS: 2040 LINGLESTOWN RD. HARRISBURG, PA l7ll0 TELEPHONE: 21 ~-24n-OqOO SUPREME COURT 10 #: ATIORNEY FOR: nllFllNnANT BY THE COURT: DATE: 1ftI, ~ ~ Deputy Seal of the Court ~ ".. .-.~ ~~~~ ,- -. . ~.-,.~ ';~~-- Ir::~t .., 10'1\ ,"j L.JJ ',',-,. )-;:,,;,;;, -,- '."--ll-:', EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: AESTHETIC & RECONSTRUCTIVE SUR 816 BELVEDRE STREET CARLISLE, P A 17013 RE: 95439 TAMIE LE STUMP AlKlA TAMIE LEA Any and all records, correspondence, files and memorandums, handwritten notes, biIling and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: TAMm LE STUMP A/KlA TAMm LEA MILLER, MT. HOLLY SPRINGS, PA 17065 Social Security #: 206-56-2270 Date of Birth: 03-22-1962 SUlO-377090 95439-L1B ~~~V!iii~~l;"i-i'ilil~"'~l,ai~~iii~l:i!}ji'l;J'~(Wj"~,,,~~.\i'ilAi "C]ltl'c.,.lC~J.IL.J"JlJ~m;'l:\"-"" _~,' ,,'" ,""'~"_C .1--~\""-1'__,"?'V'-",",,,-,,,,,,^-, ,-Of- _Y._~'~ __ ," ,"'Po'" "!'~____">' --,-,''',,, __;'R>,"";.11,,jl~'ill~Co'-"""'-''''''''''''"-=- --,-""-'"' ",~,,~" ~,"",.. ,-?> , -- ~. ,- -- ,,~ ~--litl'!lilliti -,iiltdlLdt! -.',"~~-","~--'.~~~. --, ,-~ '~-' ~ .- "'1'1;'---, ~.9j D} ~ ~C~:; :::C) ,>~~ 5 ~, '. o ~ lIDl'A'1Tl_ a t\,) o " , c:: ..2t: :0 C,) ':;) -'-]lt1 '~} CJ 'n) , ..lel -,"f- -o-'----r4 ~_)h~ ~o OI'T] ';;! :lJ -.:; :-<::> - ~ ':..> rn .~-" ~~ "", .~