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HomeMy WebLinkAbout03-2289BARBARA L. BAIR and : COURT OF COMMON PLEAS ROLAND W. BAIR, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs ?1 DOCKET NO.03- CV-2003-CV V. : CIVIL - IN LAW JANICE R. VAJDA and ANDREA L. VAMA : q eve- JURY TRIAL DEMANDED 35 o 9 Co u,,fkys 4e efendants C??M p? J1, ??.-70i/ PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue Writs of Summons in the above captioned action. X Writ of Summons shall be issued and forwarded to () Attorney (X) Sheriff May 13, 2003 61 Luther E. Milspaw, r., squire Supreme Ct. ID No: P 19226 130 State Street, P.O. B x 946 Harrisburg, PA 17108- 946 (717) 236-3141 Voice (717) 236-0791 FAX Lmilspaw@mblawfirm.com WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. Date: 771 Prothonotar- BY ax h?,pD, Deputy CNO V ??- f. tr _ SHERIFF'S RETURN - REGULAR CASE NO: 2003-02289 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BAIR BARBARA L ET AL VS VAJDA JANICE R ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS VAJDA JANICE R was served upon the DEFENDANT , at 2005:00 HOURS, on the 14th day of May 2003 at 3509 COUNTRYSIDE LANE CAMP HILL, PA 17011 JANICE R VAJDA a true and attested copy of WRIT OF SUMMONS by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this /G ? day of 2" a 3 A. D. Prothonotary '/_ So Answers: R. Thomas Kline 05/15/2003 LUTHER MILSPAW JR By: Deputy S iff SHERIFF'S RETURN - REGULAR CASE NO: 2003-02289 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BAIR BARBARA L ET AL VS VAJDA JANICE R ET AL 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 VAJDA ANDREA L DEFENDANT the at 2005:00 HOURS, on the 14th day of May , 2003 at 3509 COUNTRYSIDE LANE CAMP HILL, PA 17011 JANICE R VAJDA, MOTHER by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this lG day of .200-3 A . D . rothonotary So Answers: R. Thomas Kline 05/15/2003 LUTHER MILSPAW JR By: Deputy S iff BARBARA L. BAIR and ROLAND W. BAI R, Plaintiffs, V. JANICE R. VAJDA and ANDREA L. VAJ DA, Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 03-2289 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Janice R. Vajda and Andrea L. Vajda, with regard to the above-captioned matter. Respectfully submitted, Date: NEALON & GOVER, P.C. By: James G. Nealon, III, Esquire I . D. #: 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE XN-- AND NOW, this V day of May, 2003, 1 hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Luther E. Milspaw, Jr., Esquire 130 State Street, P.O. Box 946 Harrisburg, PA 17108-0946 JAMES G. NEALON, III, ESQUIRE C C-) f t 0 '` BARBARA L. BAIR and ROLAND W. BAIR, Plaintiffs, V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 03-2289 JANICE R. VAJDA and ANDREA L. CIVIL ACTION - LAW VAJ DA, Defendants. JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER, P.C. By: James G. Nealon, III, Esquire I.D. #: 46457 2411 North Front Street Harrisburg, PA 17110 Date: 717/232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: 2ToZ?3 0 ?. ?4-' P rothonotarv ? Q N `P C 3' `n o1? BARBARA L. BAIR and : COURT OF COMMON PLEAS ROLAND W. BAIR, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : DOCKET NO. 03-2289 -CV-2003-CV V. : CIVIL - IN LAW ANDREA L. VAJDA and JANICE R. VAJDA, : JURY TRIAL DEMANDED Defendants NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action with in twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 or 1-800-990-9108 BARBARA L. BAIR and ROLAND W. BAIR, Plaintiffs V. ANDREA L. VAJDA and JANICE R. VAJDA, Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 03-229 -CV-2003-CV CIVIL - IN LAW JURY TRIAL DEMANDED NOTICIA LE RAN DEMANDADO A USTED EN LA CORTE. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dial de plazo at partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted nose defiende, la sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para. usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17013 (717) 249-3166 or 1-800-990-9108 BARBARA L. BAIR and : COURT OF COMMON PLEAS ROLAND W. BAIR, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs DOCKET NO. 03-2289 -CV-2003-CV V. CIVIL - IN LAW ANDREA L. VAJDA and JANICE R. VAJDA : JURY TRIAL DEMANDED Defendants COMPLAINT NOW COME, Plaintiffs Barbara L. Bair and Roland W. Bair, by and through their attorney, Luther E. Milspaw, Jr., and in support of this Complaint state: FACTS COMMON TO ALL COUNTS 1. Barbara Bair is an adult individual with a residence address of 77 Beechcliff Drive, Carlisle, Pa., 17013. 2. Roland Bair is an adult individual who is the husband of Barbara Bair, with a residence address of 77 Beechcliff Drive, Carlisle, Pa., 17013. 3. The Defendant, Janice R. Vajda, is an adult individual with a residence address of 3509 Countryside Lane, Camp Hill, Pa., 17011. 4. The Defendant, Andrea L. Vajda, is an adult individual with a residence address of 3509 Countryside Lane, Camp Hill, Pa., 17011. 5. On May 14, 2001 Plaintiff Barbara Bair was traveling eastbound on SR-114 in Silver Spring Township, Cumberland County, Pennsylvania, operating a vehicle identified as a 1987 Buick Park Avenue, license plate number APN3697, registered in Pennsylvania. 6. At that date and time, Defendant Andrea Vajda ("driver") was operating a 1996 Mazda Protege, with the license plate number DYZ6417, registered in Pennsylvania, heading westbound on T- 587, also in Silver Spring Township, Cumberland County, Pennsylvania, with Defendant Janice Vajda as her passenger ("passenger"). 7. The car driven by Defendant Andrea Vajda was owned and insured by Defendant Janice Vajda at the time. 8. At approximately 5:50PM in the afternoon of May 14, 2001, as Plaintiff Barbara Bair was traveling east bound on SR-114 and was crossing the intersection of SRI 14 with T-587, and having the right of way in her favor, she was struck by the Defendants' vehicle as the Defendants attempted to cross SR-114 and continue on T-587 westbound. 9. The Defendants were stopped at a stop sign at the intersection of T-587 and SR- 114 when the Plaintiff Barbara Bair approached the same intersection. 10. The Defendant driver pulled out from the stop sign, while talking to her passenger, failed to see the Plaintiffs vehicle and hit it. The conduct of the Defendants in hitting the Plaintiffs vehicle was negligent, careless, and reckless. 11. As a direct and proximate result of the negligent, careless, and reckless conduct of the Defendant driver, and the combined negligent, reckless, and careless conduct of the Defendants, the Plaintiff Barbara Bair suffered serious injuries. 12. As a direct and proximate result of the injuries received as a result of the collision on May 14, 2001, the Plaintiff Barbara Bair has been unable to resume and continue in her regular employment and has suffered wage loss as directly related thereto. 13. As a direct and proximate result of the individual and collective negligent, reckless, and careless conduct of the Defendants, Plaintiff Barbara Bair has suffered and will continue to suffer from a loss of life's pleasures and has suffered and will continue to suffer on a regular basis from physical, emotional, and mental anguish. 14. As a direct and proximate result of the individual and collective negligent, reckless, and careless conduct of the Defendants, Plaintiff Barbara Bair has incurred and will continue to incur medical costs and expenses and other financial losses. COUNT I - NEGLIGENCE PLAINTIFF BARBARA BAIR v. DEFENDANT ANDREA VAJDA 15. Paragraph 1 through 14 are incorporated herein by reference as if set forth in full. 16. The motor vehicle accident resulted in personal injuries to Plaintiff Barbara Bair which were a direct and proximate result of the negligent, reckless, and careless actions of the Defendant Andrea Vajda, which include but are not limited to the following: a. Failing to take due and proper cognizance of the other drivers on the roadway upon which she was driving; b. Operating her vehicle in a manner which was careless, willful, and with reckless indifference to the rights, safety and position of the Plaintiff, c. Failing to observe the Plaintiff's vehicle on the roadway; d. Failing to keep a reasonable lookout for other vehicles lawfully on the road; e. Failing to apply her brakes; f. Failing to apply her brakes in time to avoid the collision; g. Negligently applying her brakes; h. Failing to operate her vehicle in accordance with existing traffic conditions and traffic controls; i. Operating the vehicle in a manner which endangers persons and property, and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania; and j. Permitting her vehicle to strike the vehicle occupied by the Plaintiff Barbara Bair. 17. As a result of the force of the impact caused by the negligence, careless, and reckless acts and failures to act of the Defendant Andrea Vajda, Plaintiff Barbara Bair suffered physical injuries, including but not limited to injuries to her neck, chest, left shoulder, left forearm, left wrist, and fingers and residual injuries thereto, loss of sleep, headaches, numbness and tingling, pain, and losses associated with her range of motion. WHEREFORE, Plaintiff Barbara Bair demands that judgment be entered in favor of Plaintiff and against Defendant Andrea Vajda for compensatory and general damages in a sum in excess of twenty-five thousand ($25,000.00) dollars plus cost of suit and such other relief as this Court deems just. COUNT II PLAINTIFF BARBARA BAIR v. DEFENDANT JANICE VAJDA NEGLIGENCE 18. The foregoing paragraphs of this Complaint are incorporated herein by reference as if set forth again in full. 19. Defendant Janice Vajda, as owner of the vehicle, owed duties to the Plaintiff Barbara Bair to insure that the driver of her vehicle was properly licensed and qualified to operate the vehicle and to insure that the drive operated the vehicle in a manner that was not negligence, careless, or reckless. Defendant Janice Vajda breached these duties. 20. As a result of the force of the impact caused by the negligence, careless, and reckless acts and failures to act of the Defendant Janice Vajda, Plaintiff Barbara Bair suffered physical injuries, including but not limited to injuries to her neck, chest, left shoulder, left forearm, left wrist, and fingers and residual injuries thereto, loss of sleep, headaches, numbness and tingling, pain, and losses associated with her range of motion. WHEREFORE, Plaintiff Barbara Bair demands that judgment be entered in favor of Plaintiff and against Defendant Janice Vajda for compensatory and general damages in a sum in excess of twenty-five thousand ($25,000.00) dollars plus cost of suit and such other relief as this Court deems just. COUNT III-LOSS OF CONSORTIUM -ET AL. PLAINTIFF ROLAND V. BAIR v. DEFENDANT ANDREA VAJDA 21. The foregoing paragraphs of this Complaint are incorporated herein by reference as if set forth again in full. 22. The Plaintiff, Roland Bair, has been deprived of his wife's services in society and has expended and will be obligated to expend substantial funds to care for her and to pay for the expenses associated with her injuries. 23. As a result of the negligence of the Defendant, herein set forth, Plaintiff Roland Bair has suffered loss of consortium of his wife, emotional distress in response to his wife's condition, anxiety, and loss of enjoyment of life, all of which have been continuing, will continue in the future and are permanent. WHEREFORE, Plaintiff Roland Bair demands that judgment be entered in favor of Plaintiff and against Defendant Andrea Vajda for compensatory and general damages in a sum in excess of twenty-five thousand ($25,000.00) dollars plus cost of suit and such other relief as this Court deems just. COUNT IV- LOSS OF CONSORTIUM- ET AL. PLAINTIFF ROLAND BAIR v. DEFENDANT JANICE VAJDA 24. The foregoing paragraphs of this Complaint are incorporated herein by reference as if set forth again in full. WHEREFORE, Plaintiff Roland Bair demands that judgment be entered in favor of Plaintiff and against Defendant Janice Vajda for compensatory and general damages in a sum in excess of twenty-five thousand ($25,000.00) dollars plus cost of suit and such other relief as this Court deems just. submitted, July 16, 2003 BY Luther E. Milspaw Jr., Esquire Attorney ID # 1922 130 State Street, P.O. Box 946 Harrisburg, PA 17108-0946 (717) 236-3141; FAX (717) 236-0791 Email: Lmilspaw@mblawfirm.com Attorney for Plaintiffs BARBARA L. BAIR and : COURT OF COMMON PLEAS ROLAND W. BAIR, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs DOCKET NO. 03-2289 -CV-2003-CV V. CIVIL - IN LAW ANDREA L. VAJDA and JANICE R. VAJDA, : JURY TRIAL DEMANDED Defendants VERIFICATION I, Luther E. Milspaw, Jr., Esquire, attorney for BARBARA L. BAIR and ROLAND W. BAIR, the plaintiffs the instant action, being duly sworn according to law, deposes and says that the Plaintiffs are outside the jurisdiction of the court and their original verification cannot be obtained with the time allowed for the filing of the Complaint; that the facts set forth in the foregoing Complaint are true and correct to the best of the Plaintiffs' knowledge, information and belief, all as related to the undersigned by Plaintiffs; that an original verification shall be obtained from the Plaintiffs as soon as possible and filed with the Court; and that the undersigned understands that this Verification is made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. July 16, 2003 Lu er E. Mils Jr., Esquire CERTIFICATE OF SERVICE AND NOW, this 16th day of July, 2003, I hereby certify that on this date I served the foregoing Complaint, by depositing the same in the U.S. mail, postage pre-paid, at Harrisburg, Pennsylvania addressed as follows: James G. Nealon, III Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 July 16, 2003 BY: 121 (;Ie'? Elizabeth M. Patterson, Paralegal to Luther E. Milspaw, Jr.,Esq. r? C:: ... . ,.., ,_ (i: 2 ??,_ _ ?_ ?,.? ;? Xi _j ? _ i::? ? !.? -0 '< BARBARA L. BAIR and : COURT OF COMMON PLEAS ROLAND W. BAIR, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs DOCKET NO. 03-2289 -CV-2003-CV V. CIVIL - IN LAW ANDREA L. VAJDA and JANICE R. VAJDA, : JURY TRIAL DEMANDED Defendants PRAECIPE TO FILE VERIFICATION TO THE PROTHONOTARY: Please substitute the enclosed Verification, signed by the Plaintiff, for the attorney's verification which was filed with the Complaint on July 16, 2003. 7 July 24, 2003 e CERTIFICATE OF SERVICE AND NOW, this 24' day of July, 2003, I hereby certify that on this date I served the foregoing Praecipe to File Verification, by depositing the same in the U.S. mail, postage pre- paid, at Harrisburg, Pennsylvania addressed as follows: James G. Nealon, III Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA 17110 July 24, 2003 BY: ElizA? M. Patterson, Paralegal to Luther E. Milspaw, Jr.,Esq. BARBARA L. BAIR and : COURT OF COMMON PLEAS ROLAND W. BAIR, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs DOCKET NO. 03-2289 -CV-2003-CV V. CIVIL - IN LAW ANDREA L. VAJDA and JANICE R. VAJDA, : JURY TRIAL DEMANDED Defendants VERIFICATION I, the undersigned, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA. Section 4904 relating to unsworn falsification to authorities. Barbara L. Bair (7 C CD to n -,? BARBARA L. BAIR and ROLAND W. BAIR, Plaintiffs, V. JANICE R. VAJDA and ANDREA L. VAJDA, Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 011-2289 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Barbara L. Bair Rowland W. Bair c/o Luther E. Milspaw, Jr., Esquire 130 State Street PO Box 946 Harrisburg, PA 17108-0946 YOU ARE HEREBY NOTIFIED to file a response to the enclosed Answer with New Matter of Defendants, Andrea L. Vajda and Janice R. Vajda, within twenty (20) days of service hereof or a judgment may be entered against you. Respectfully submitted, NEALON & G R By: V James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: May 4, 2004 BARBARA L. BAIR and ROLAND W BAIR, Plaintiffs, V. JANICE R. VAJDA and ANDREA L. VAJDA, Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 03-2289 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANTS. ANDREA L. VAJDA AND JANICE. R. VAJDA 1. Admitted, upon information and belief. 2. Admitted, upon information and belief. 3. Admitted. 4. Admitted. 5. Admitted. 6. It is admitted that Defendant, Andrea Vajda, was operating a 1996 Mazda Protege, Pennsylvania license number DYZ6417, in a westbound direction on T-587, Silver Spring Township, Cumberland County, Pennsylvania. It is denied that Janice Vajda was a passenger in the motor vehicle. On the contrary, Brad Quarello was the passenger. 7. Admitted. 8. Admitted. 9. Admitted. 10. It is admitted that Defendant Vajda pulled from the stop sign, while talking to the passenger, failed to see the Plaintiff's vehicle and hit it. The remaining averments contained in Plaintiff's Complaint are conclusions of law to which no response is required. 11. - 14. Denied pursuant to Pa.R.C.P. 1029(e). COUNTI NEGLIGENCE PLAINTIFF, BARBARA L. BAIR V DEFENDANT, ANDREA VAJDA 15. Paragraphs 1 through 14 above are incorporated herein by reference. 16.-17. Denied pursuant to Pa.R.C.P. 1029(e). COUNT II PLAINTIFF. BARBARA L. BAIR V DEFENDANT, JANICE R. VAJDA 18. The averments contained in Paragraphs 1 - 17 above are incorporated herein by reference. 19.-20. Denied pursuant to Pa.R.C.P. 1029(e). COUNT III LOSS OF CONSORTIUM PLAINTIFF. ROLAND W. BAIR V. DEFENDANT, ANDREA L. VAJDA 21. Paragraphs 1 - 20 above are incorporated herein and by reference. 22.-23. Denied pursuant to Pa.R.C.P. 1029(e). COUNT IV LOSS OF CONSORTIUM PLAINTIFF. ROLAND W. BAIR V DEFEND ANIT, JANICE R. VAJDA 24. The averments contained in Paragraphs 1 - 23 above are incorporated herein and by reference. NEW MATTER 25. This Complaint fails to state a cause of action upon which relief can be grated against Janice R. Vajda. 26. Any damages to which the Plaintiffs are entitled are to be reduced in whole, or in part, in accordance with the Pennsylvania Motor Vehicle Financial Responsibility Act, 75 Pa. C.S.A. Section 1701 at seq. 27. The claim of Plaintiff, Roland W. Bair, for Motion to Stress Damages is not a recognized cause of action in Pennsylvania. WHEREFORE, Defendant, Andrea L. Vajda and Janice R. Vajda, urge this Honorable Court to enter judgment in their favor. Respectfully submitted, NEALON & GOVT p By: Date: James G. lVealon, III, Esquire I.D. #: 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this 4th day of May, 2004, 1 hereby certify that I have served the foregoing INTERROGATORIES on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Luther E. Milspaw, Jr., Esquire 130 State Street, P.O. Box 946 Harrisburg, PA 17108-0946 71T4- James G. Nealon, III, Esquire VERIFICATION I, ANDREA L. VAJDA, verify that the statements made in the foregoing ANSWER WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: --- ANDREA L. VAJDA VERIFICATION I, JANICE R. VAJDA, verify that the statements made in the foregoing ANSWER WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date:- c-i C c r n r ! Z ? -., m GD -': LUTHER E. MILSPAW, JR., ESQUIRE Attorney II1# PA 19226 130 State Street P.O. l Box 94946 6 Harrisburg, Attorney for Plaintiffs BARBARA L. BAIR and ROLAND W. BAIR, Plaintiffs V. ANDREA L. VAJDA and JANICE R. VAJDA, Defendants COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 03-2289 -CV-2003-CV CIVIL - IN LAW JURY TRIAL DEMANDED AND NOW this 18°i day of May, 2004, come plaintiffs by their attorney Luther E. Milspaw, Jr., Esquire, and reply to the New Matter of Defendants, as follows: 25 - 27. Denied. The allegations of paragraphs 25 through 27 of the New Matter of Defendants constitute legal conclusions to which no response its required. To the extent the allegations in New Matter constitute factual conclusions or mixed conclusions of law and fact, said allegations are denied. s request that the New Matter of Defendants be dismissed. WHEREFORE Plaintiff Respectfully submitted, May 19, 2004 Esquire Attorney I.D. No. 1 226 130 State Street, P- V. Box 946 Harrisburg, PA 171V-0946 Attorney for Plaintiffs BARBARA L. BAIR and ROLAND W. BAIR, Plaintiffs V. ANDREA L. VAJDA and JANICE R. VAJDA, Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 03-2289 -CV-2003-CV CIVIL - IN LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that on May 19 , 2004, a true and correct. copy of Reply to New Matter was served by regular mail upon the following: May 19, 2004 James G. Nealon, III Nealon & Gover, P.C. 2411 North Front Street Harrisburg, PA. 17110 Attorneys for Defendants o CC o r ? _ ?ri c z?c7 00 Ci !m ? O CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR -VS- VAJDA COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 07/22/2004 M on beh ofL? G? L N, III, ESc ttorney or DEFENDANT DE11-506139 5 7 8 2 2- L 0 1 C O M M O N W E A L T H OP P E N N S'Y L VANS A COUNT "Y OP C UM S E R LAN D IN THE MATTER OF: COURT OF COMMON PLEAS BAIR -VS- VAJDA )F INTENT TO FOR TERM, CASE NO: 03-2289-CV-2003-CV MA TO PRODUCE MARGARET Y. GROFF, M.D_ ORTHO SURGEONS OF CENTRAL CARLISLE HOSPITAL HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S_ ZIMMERMAN, M.D. MEDICAL RECORDS PA MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS ) RLfLE 4009.21 TO: LUTHER E. MILSPAN, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/02/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-271329 57822-C!03- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR vs. VAJDA File No. 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MARGARET Y. GROFF. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.- 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G. NEALON, III, ESO. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ,!!1!- 2 2 2004 Date: y?e Seal of the Court BY THE COURT: Prothonotary/Clerk, Civi ivision Dep 57822-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MARGARET Y. GROFF, M.D. 310 NORTH SALEM CHURCH RD MECHANICSBURG, PA 17050 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians,, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: I1-18-1954 SU10-511732 5 7 6 2 2- 1, 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, _VS_ CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 07/22/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-506140 57822-L 02 C O M M O NW E A L T H OP C O UN T Y OP IN THE MATTER OF: BAIR -VS- VAJDA TO MARGARET Y. GROFF, M.D. ORTHO SURGEONS OF CENTRAL PA CARLISLE HOSPITAL HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. TO MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV DOC TENTS TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/02/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. -.03-311 Any questions regarding this matter, contact P E NN S Y L VAN 2 A C UMBER LAN D THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-271329 5 7 8 2 2- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR VAJDA vs. File No. 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHO SURGEONS OF CE.NTR4L PA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G. NEALON, III, ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 2 2 2004 Date: ?ZO dZCfhY Seal of the Court BY THE COURT: AV / ..P . Prothonotary/Clerk, Civi Division Deputw/ 57822-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHO SURGEONS OF CENTRAL PA 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE RECORDS FROM ROBERT MAUER, M.D. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security f{: 181-38-5253 Date of Birth: 11-18-1954 SU10-511734 57822-L 02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS - CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 07/22/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-506141 57822-T,03 C O M M O N W E A L T H or P E NN S Y L VAN = A COUNTY OP C UM B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS BAIR -VS- VAJDA TO MARGARET Y. GROFF, M.D. ORTHO SURGEONS OF CENTRAL PA CARLISLE HOSPITAL HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. TERM, CASE NO: 03-2289-CV-2003-CV TO PRODUCE DOCUMENTS A TA RITF R 4009.21 MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/02/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-271329 57822-C:!03- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR vs. V AJDA File No. 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 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: **** SEE ATTACHED RIDER **** at The MCS Croup Inc 1601 Market Street. Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G. NEALON, III, ESO. ADDRESS: 2411 N FRONT STREET HARRISBURG PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ,1 L 2 2 2004 Date: av Seal of the Court BY THE COURT: Js/ LA -5 Prothonotary/Clerk, Civil Division Deputy ? 57822-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE RECORDS FROM EMERGENCY ROOM Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history =physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security 1{: 181-38-5253 Date of Birth: 11-18-1954 £IU10-511736 57822-L 03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS - CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 07/22/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-506142 5 7 8 2 2- L 0 4 C O M M O N W E AL T H COUNTY IN THE MATTER OF: BAIR -VS- VAJDA TO MARGARET Y. GROFF, M.D. ORTHO SURGEONS OF CENTRAL CARLISLE HOSPITAL HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S_ ZIMMERMAN, M.D. TO MEDICAL RECORDS PA MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/02/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 Any questions regarding this matter, contact or P E NN S Y L VAN 2 A Or C U M B E R L AN D THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-271329 5 7 8 2 2- C O 3- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR VAJDA vs. File No. 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HAND THERAPY ASSOCIATION (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G. NEALON. III. ESQ. ADDRESS: 2411 N FRONT STREET HARRISBURG. PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant J U L 2 2 2004 Date: 3D, y' Seal of the Court BY THE COURT: ?Sf 4 - Prothonotary/Clerk, Civil tvision Deputy G? 57822-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HAND THERAPY ASSOCIATION 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE RECORDFS FROM DONINE SHAFFER, OTR/L Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians., files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: 11-18-1954 SU10-511738 57822-1,04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS- CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 07/22/2004- JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-506143 5 7 8 2 2- L 0 5 C O M M O N W E A L T H OP COUNT Y OP IN THE MATTER OF: BAIR -VS- VAJDA TO MARGARET Y. GROFF, M.D. ORTHO SURGEONS OF CENTRAL PA CARLISLE HOSPITAL HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS I:lZl17 TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/02/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 Any questions regarding this matter, contact P E NN S y L VAN T A C U M S E R L AN D COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-271329 57822-C01- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR File No. 03-2289-CV-2003-CV VS. VAJDA SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT 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: **** SEE ATTACHED RIDER **** at The MCS Group. Inc- 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G. NEALON. III. ESQ. ADDRESS: 2411 N. FRONT STREET HARRISBURG. PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civi ivision ! U ?1_ 2 2 2004 ??, Deputy Date: ? 3D o7dEay Seal of the Court 57822-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic, form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: BARBARA L. BAIR 77 BEECHCLHT DR., CARLISLE, PA 17013 Social Security fit: 181-38-5253 Date of Birth: 11-18-1954 SU10-511740 5 7 8 2 2- L O 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, _VS_ CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 07/22/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-506144 5 7 8 2 2- 1, 0 6 C O M M O N W E A L T H or COUNTY OF IN THE MATTER OF: BAIR -VS- VAJDA NOTICE OF INTENT TO MARGARET Y. GROFF, M_D. ORTHO SURGEONS OF CENTRAL PA CARLISLE HOSPITAL HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. TO MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV .21 TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/02/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 Any questions regarding this matter, contact P E NN S Y L VAN = A CUMBER LAN D THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-271329 57822-C:03- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR VAJDA VS. File No. 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PRISM (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street. Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G. NEALON. III. ESO. ADDRESS: 241 1 N. FRONT STREET HARRIS TR PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 2 2 2004 Date: 30 dcf° Seal of the Court BY THE COURT: /f/ Gle ? - Prothonotary/Clerk, CiviPDivision Depute 57822-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PRISM 175 LANCASTER BLVD. P. O. BOX 2028 MECHANICSBURG, PA 17055 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE RECORDS FROM DANIEL DEFALCIS, MD, FAAPMR Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLHT DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: 11-18-1954 SU10-511742 57822-L 06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS- CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 07/22/2004 JAMES G.- NEALON, III, ESQ. Attorney for DEFENDANT DE11-506145 5 7 8 2 2- L O 7 C O M M O N W E A L T H OF P E N N S Y L VAN 2 A COUNTY OF C UM B E R:L AN D IN THE MATTER OF: COURT OF COMMON PLEAS BAIR -VS- VAJDA OF INTENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TERM, CASE NO: 03-2289-CV-2003-CV PRODUCE MARGARET Y. GROFF, M_D. ORTHO SURGEONS OF CENTRAL PA CARLISLE HOSPITAL HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S_ ZIMMERMAN, M.D. TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/02/2004 MCS on behalf of CC: JAMES G. NEALON, III, ESQ. - 03-311 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-271329 5 7 8 2 2- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR VS. VAJDA File No. 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DAVID S. ZIMMERMAN. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouv Inc 1601 Market Street_ Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G. NEALON. III. ESO. ADDRESS: 2411 N FRONT STREET HARRISBURG. PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AL L 2 2 2004 Date: ?0Q?Y Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil tvision Vie' Dep 57822-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID S. ZIMMERMAN, M.D. 6 MARKET PLAZA WAY FAMILY INTERNAL MED MECHANICSBURG, PA 17055 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLHT DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: 11-18-1954 SU10-511744 5 7 8 2 2- 1, 0 7 (? N :- ni a73 GJ CI, xJ -< CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR -VS- VAJDA COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, :[II, 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: 08/02/2004 MC8?ori beha f l G L III, ES torney for DEFENDANT DE11-507930 5 7 8 2 2- L 0 8 C O MM O NW E AL T H OF PE NN E; Y L VAN 2 A COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS BAIR TERM, -VS- VAJDA NOTICE OF INTENT TO SILVERCREER FAMILY PHYSICIANS ORTHOPAEDIC SURGEONS OF CARLISLE HOSPITAL EMERGENCY RM HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. TO MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS CASE NO: 03-2289-CV-2003-CV AND TO: LUTHER E. MILSPAN, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/12/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 TIMOTHY SHAFFER Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-272325 5 7 8 2 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY.OF CUMBERLAND BAIR VS. VAJDA File No. _ 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SILVERCREFK FAMILY PHYSICIANS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS CIL= Inc 1601 Mffket Street Suite 800. Philadelphia. PA 15103 - 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: JAMES G NEALON. III. ESQ. ADDRESS: 2411 N FRONT STREET HAMSRi1RG PA 17101 TELEPHONE: (??15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY E COURT: )iVil Prothonotarv/Cle r AUG 0 2 7004 Deputy Date: i ; G= Seal of the Court 57822-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR SILVERCREEK FAMILY PHYSICIANS MARGARET Y. GROFF, M.D. 310 N. SALEM CHURCH MECHANICSBURG, PA 17055 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: I1-18-1954 SU10-513288 S 7 8 2 2- L O 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS- CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 08/02/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-507931 5 7 8 2 2- L 0 9 C O M M O NW E AL T H OF COUNTY OF IN THE MATTER OF: BAIR -VS- VAJDA NOTICE OF INTENT SILVERCREER FAMILY PHYSICIANS ORTHOPAEDIC SURGEONS OF CARLISLE HOSPITAL EMERGENCY RM HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/12/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 TIMOTHY SHAFFER - Any questions regarding this matter, contact P E NN :3 Y L VAN 2 A C U M B EI2LANI) THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-272325 5 7 8 2 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR vs. VAJDA File No. _ 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPAEDIC SURGEONS OF (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Marker Street- Suite 800. Philadelphia. PA I d 03 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: JAMES G. NEALON. III. ESO. ADDRESS: 2411 N FRONT STREET HARRISBURG PA 17101 TELEPHONE: f2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 0 2 7004 Date: j1A? Seal of the Court BY THE COURT: ProthonotaryIClerk, ivi ivi Deputy 57822-09 EXPLANATION OF REQUIRED ]RECORDS TO: CUSTODIAN OF RECORDS FOR ORTHOPAEDIC SURGEONS OF CENTRAL PA LTD 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: 11-18-1954 SU10-513290 57822-L 09 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS - CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 08/02/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-507932 57822-L 3-0 COMMONWEALTH Or P E NN 53Y L VAN = A COUNTY OF C UM B E IZ LAN D IN THE MATTER OF: BAIR -VS- VAJDA COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV 2 SILVERCREER FAMILY PHYSICIANS ORTHOPAEDIC SURGEONS OF CARLISLE HOSPITAL EMERGENCY RM HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/12/2004 CC: JAMES G. NEALON, III, ESQ. - 03-311 TIMOTHY SHAFFER - Any questions regarding this matter, contact MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-272325 5 7 8 2 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR vs. VAJDA File No. _ 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE HOSPITAL EMERGENCY RM (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 M k t Street Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G NEALON. III. ESQ. ADDRESS: 2411 N FRONT STREET HARRISBURG-PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG Q 2 Anne Date: J?- Seal of the Court LVPULy 57822-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL EMERGENCY RM 246 PARKER ST. CARLISLE, PA 17013 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: 11-18-1954 SU10-513292 57822-T,3-0 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS- CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 08/02/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-507933 57822-L 3-1 C O M M O NW E AL T H OF COUNTY OF IN THE MATTER OF: BAIR -VS- VAJDA SILVERCREER FAMILY PHYSICIANS ORTHOPAEDIC SURGEONS OF CARLISLE HOSPITAL EMERGENCY RM HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/12/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 TIMOTHY SHAFFER Any questions regarding this matter, contact P E NN E3Y L VAN 2 A CUMBBFtLAND THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-272325 5 7 8 2 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR vs. VAJDA File No. _ 03-2289-CL7-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HAND THERAPY ASSOCIATION (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Gwun. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G NEALON. III. ESO. ADDRESS: 2411 N FRONT STREET HARRISBURG PA 17101 TELEPHONE: rat 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk Civil Divis& AUG Q 9 9nn4 Deputy Date: L4 e,?? Seal of the Court 57822-I1 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HAND THERAPY ASSOCIATION 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING RECORDS OF DONINE SHAFFER, OTR/L. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: I1-18-1954 SU10-513294 5 7 8 2 2- L 1-3- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS - CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, :III, 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: 08/02/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-507934 5 7 8 2 2- 1, 1 2 COMMONWEALTH OF P E NN E; Y L VAN T A COUNT Y OF C UM B E FZ LAN D IN THE MATTER OF: BAIR -VS- VAJDA SILVERCREER FAMILY PHYSICIANS ORTHOPAEDIC SURGEONS OF CARLISLE HOSPITAL EMERGENCY RM HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/12/2004 CC: JAMES G. NEALON, III, ESQ. - 03-311 TIMOTHY SHAFFER MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-272325 57822-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR VS. VAJDA File No. _ 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT 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: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite unn Philad lphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G NEALON. III. ESO. ADDRESS: 2411 N FRONT STREET HAMSRURG- PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 0 2 2004 Date: c /! l o?Ol??f Seal of the Court BY Tj?E COURT: Prothonotary/Clerk, Civi Div' i Deputy 57822-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary :restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIPF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: 11-18-1954 SU10-513296 5 7 8 2 2- 1, 3-2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, -VS - CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 08/02/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-507935 5 7 8 2 2- L 3_3 C O M M O N W E AL T H COUNTY IN THE MATTER OF: BAIR -VS- VAJDA SILVERCREER FAMILY PHYSICIANS ORTHOPAEDIC SURGEONS OF CARLISLE HOSPITAL EMERGENCY RM HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. A MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/12/2004 MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT CC: JAMES G. NEALON, III, ESQ. - 03-311 TIMOTHY SHAFFER Any questions regarding this matter, contact OF PENNS:YLVAN=A OF CUMBEF;LAND THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-272325 5 7 8 2 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR File No. _ 03-2289-CV-2003-CV VS. VAJDA SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PRISM (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun. Inc.. 1601 Market Street. Suite 800_ Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G NEALON. III. ESO. ADDRESS: 2411 N FRONT STREET HARRiSRi1R0 PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant OY2004' Date: ??j V d' a?y Seal of the Court BY THE COURT: _J1 . k--?4 Prothonotary/Clerk, Civil Divisi D, Deputy 57822-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PRISM 175 LANCASTER BLVD. P. O. BOX 2028 MECHANICSBURG, PA 17055 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING RECORDS OF DANIEL C. DEFALCIS, M.D., FAAPMR Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security i/: 181-38-5253 Date of Birth: 11-18-1954 SU10-513298 5 7 8 2 2- L 1 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: BAIR VAJDA COURT OF COMMON PLEAS TERM, _VS_ CASE NO: 03-2289-CV-2003-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JAMES G. NEALON, III, 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: 08/02/2004 JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT DE11-507936 5 7 822 -L 1 4 C O M M O NW EAL T H OF P E NN E; Y L VAN 2 A COUNTY OF CUMBEF:.LAIVD IN THE MATTER OF: BAIR -VS- VAJDA TO SILVERCREER FAMILY PHYSICIANS ORTHOPAEDIC SURGEONS OF CARLISLE HOSPITAL EMERGENCY RM HAND THERAPY ASSOCIATION HOLY SPIRIT HOSPITAL PRISM DAVID S. ZIMMERMAN, M.D. MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 03-2289-CV-2003-CV TO: LUTHER E. MILSPAW, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of JAMES G. NEALON, III, 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: 07/12/2004 CC: JAMES G. NEALON, III, ESQ. - 03-311 TIMOTHY SHAFFER Any questions regarding this matter, contact MCS on behalf of JAMES G. NEALON, III, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-272325 5 7 8 2 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BAIR VS. V AJDA File No. _ 03-2289-CV-2003-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DAVID S ZIMMERMAN. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun Inc 1601 Market Street Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving 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: JAMES G NEALON III. ESO. ADDRESS: 2411 N FRONT STREET HARRISBURG PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 0 2 2004 Date: Seal of the Court BY TIj? COURT: Pr?othhoJnnootary/Clerk, Civil Divis,24 Deputy 57822-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID S. ZIMMERMAN, M.D. 6 MARKET PLAZA WAY FAMILY INTERNAL MED MECHANICSBURG, PA 17055 RE: 57822 BARBARA L. BAIR Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BARBARA L. BAIR 77 BEECHCLIFF DR., CARLISLE, PA 17013 Social Security #: 181-38-5253 Date of Birth: 11-18-1954 SU10-513300 5 7 8 2 2- L 1 4 f'"'1 o O Ty„ ? -I? T ? n rn -6y '" Yr BARBARA L. BAIR and : COURT OF COMMON PLEAS ROLAND W. BAIR, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs DOCKET NO. 03-2289 -CV-2003-CV v. CIVIL - IN LAW ANDREA L. VAJDA and JANICE R. VAJDA, : JURY TRIAL DEMANDED Defendants STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiffs, BARBARA L. BAIR and ROLAND W. BAIR, intend to proceed with the above-captioned matter. Respectfully sub itted, PHE4R. IL PAW, r Attorney ID No. 19226 130 State Street P.O. Box 946 Harrisburg, PA 17108-0946 (717) 236-3141 Attorney for Plaintiffs Dated: October 31, 2007 Y ' BARBARA L. BAIR and ROLAND W. BAIR, Plaintiffs V. ANDREA L. VAJDA and JANICE R. VAJDA, Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 03-2289 -CV-2003-CV CIVIL - IN LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the above Statement of Intention to Proceed upon all counsel/parties of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, on the 31' day of October, 2007, addressed as follows: Casey G. Shore, Esquire Nealon, Gover, & Perry 2411 North Front Street Harrisburg, PA 17110 Respec lly submitted, a? T L. EBRIGHT, Paralegal La ffice of Luther E. Milspaw, Jr. 30 State Street P.O. Box 946 Harrisburg, PA 17108-0946 (717) 236-3141 C'7 r`' ?m ? a? _. ? ? ? ,' ? -? C? V r. --_ .? F .-.) __ : P1 . ?. ntw ? ?? ? .. ?„ ..,?