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HomeMy WebLinkAbout01-05373IN TIIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action- ( )Law ( )Equity ,t.~Y,~ C~,~~y ~~ p / ~Jr/~ ~"a0 %~so~ ~i %~ itGC , SAS, d'A ~ 7 iiv C~/~- ski 5as~~ Plaintiff(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. Defendants) & Address(es) Writ of Summons shall be issued and forwarded to ( )Attorney (~he 'ff Name /Address /Telephone No. of Attorney ~7r.A/ndrecd Cl~a~les S~-o~~ versus fJ~ 1/ Q ~l k° C~ ~1 e (.J ~~. f~7~chart~ ~s6~~, ®6f i7ps5 l ~hortp ~ ~~~-/ 9?- 93ao) //~ Signature of4~ncy Supreme Court ID No. Date: ~~~~~_ WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE CONIl~tENCED AN ACTION AGAINST YOU. n Prothonotary n l,~ Date: 7"- P, , ~ `F ~9y/ by ~t,uc~ Gi. /VLc.(%L' et_, Deputy ( )Check here if reverse is issued for additional information. 'd~r' ..fr~6dE'waw.Y1~+.3~E+iN'~t~tit~YLW&h6ki~t=.u.~V[isrYY.rsrv.lmtr~.~s id_~, ks ~ ~ -5~i5156Y$1i' '~YSi&aM ~Fi ~ ~.'~. ~ '~"° - ~~~ •~--Y=-'- `J ~ 1 ~ /1.\ V~ o, ~ fllEn ~ 'TI ~ ~_'` ~ G ~ ~j "~ J~~~ Cam. re ~ ~, - { d~` _~ ~ ~ ... ~K - SHERIFF'S RETURN - REGULAR CASE NO: 2001-05373 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOYLE LORI COGLEY VS STRONG ANDREW CHARLES RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon STRONG ANDREW CHARLES the DEFENDANT at 1932:00 HOURS, on the 19th day of September, 2001 at 15 VALLEY VIEW DR MECHANICSBURG. PA 17055 ANDREW STRONG by handing to 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 18.00 Service 6.50 Affidavit .00 Surcharge 10.00 .00 34.50 So Answers: ~~ R. Thomas Kline 09/20/2001 LORI COG Sworn and Subscribed to before By: me this ;1k~~ day of p a.ovl A.D. ~1 n Prothonotary ~, THOMAS, THOMAS &HAFER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. NO. 01-5373 ANDREW CHARLES STRONG, Defendant CIVIL ACTION -LAW ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Jeffrey B. Rettig, Esquire, and Thomas, Thomas & Hafer, LLP on behalf of Defendant Andrew Charles Strong in the above-captioned matter. Respectfully submitted, THOINAS, THOMAS &HAFER, LLP B. Rettig, Esquire CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United. States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 Date: t ~~'~ By: THOMAS, THOMAS & HAFER, LLP J~~ `i`/'~ ca ~ -~; c - ~, ° -v ~°:? (Tt rsl ~ : ~ - ---d -,_ Vq ~.,, ~ -,~:I -C t i_ :.,fir _ ; ~~J ~ ~fTi G ~i _ t3! =` THOMAS THOMAS &HAFER LLP r~ S :.e ~_, ~ - , , ey: Jeffrey 8. Rettig, Esquire n,n Identification No. 19616 z~r ,,; -- 305 North Front Street P.O. Box 999 ~~! ~ °~~ Harrisburg, PA 17108-0999 c (717) 255-7639 d Attorney for Defendant "~ G" LORI COGLEY DOYLE, Plaintiff v. ANDREW CHARLES STRONG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-5373 CIVIL ACTION -LAW PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days of service of said Rule, or suffer a judgment of non pros pursuant to Pa.R.C.P. 1037(a). THOMAS, THOMAS &HAFER, LLP Jeffr .Rettig, Esqui / Co sel for Defendant DATE: 1 C~I g J t1( RULE TO FILE COMPLAINT NOW, l~c~i~- 023 , 2001, RULE ISSUED AS ABOVE. Prothonotary Deputy CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 THOMAS, THOMAS & HAFER, LLP ,., ' f ~ By: /~ /!~/~ + Je ettig, Esquir Date: b/ a~ n ~ ~~ c. - =, o -o u, n - m~r; .,a z~ N cn ~ , c:; ,r, r '_T) -G GS'• i THOMAS, THOMAS & HAFER, LLP By.' Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front"Street P.O. Box 999 Harrisburg, PA 17108-0999 (7f 7) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. NO. 01-5373 ANDREW CHARLES STRONG, CIVIL ACTION -LAW Defendant AND NOW, comes the Defendant, by his attorneys, Thomas, Thomas & Hafer, LLP, and files this Praecipe for Entry of Judgment of Non Pros, pursuant to Pa. R.C.P. 1037(a) based on the following considerations: 1. This case was initiated by the filing of a Writ of Summons by Plaintiff on or about September 14, 2001. 2. On October 23, 2001, the Court issued a Rule to File Complaint upon Plaintiff. 3. On October 26, 2001, counsel for Defendant served the executed Rule to Fle Complaint on Plaintiff which allowed Plaintiff twenty (20) days within which to file a Complaint. A copy of the correspondence transmitting the Rule is attached hereto and marked as Exhibit "A". ,;, _, ~ . a 4. On November 21, 2001, counsel for Defendant served Plaintiff with the Pa. R.C.P. 237.1 (a)(2) Notice Of Intent to Take a Non Pros. A copy of said "Notice" is attached hereto and marked as Exhibit "B". 5. To date, no Complaint has been filed by the Plaintiff in this action, which is in violation of Pa. R.C.P. 1037(a). WHEREFORE, Defendant respectfully requests your Honorable Court to enter a Judgment of Non Pros against Plaintiff, and discontinue this action without costs or judgment to Defendant for Plaintiff's failure to file a Complaint in this action pursuant to the Pennsylvania Rules of Civil Procedure. Date: jZ~~f,J~ ~ THOMAS, THOMAS cYL HAFER, LLP ATTORNEYS AT LAW JOSE''-PH P. HAFER LAMES K. THOMAS, II ROBERTSON B. TAYLOR IEFPREY B. RETTIG PETER I. CURRY R. BURKE McLEMORE, 1R. EDWARD H. JORDAN, IR. C. KENT PRICE RANDALL G. GALE DAVID L. SCHWALM PETER J. SPEAKER DOUGLAS B. MARCELLO PAUL I. DELLASEGA SARAH W. AROSELL EUGENE N. MCHUGH 305 NORTH FRONT STREET SIXTH FLOOR P.O. BOX 999 HARRISBURG, PA 17108 (717)237-7100 FAX (717) 237-7105 WRITER'S DIRECT DIAL NUMBER (717)255-7639 JBR@tthlaw.com STEPHEN E. GEDULDIG KAREN S. COATES TODD B. NARVOL LAMES 7. DODD-O DANIEL L. GRILL JOHN J. MCNALLY, 711 KEVIN C. McNAMARA BROOKS R. FOLAND JONATHAN C. DEISHER SOHN FLOUNLACKER JOHN T. HUSKIN, 1R. MICHELE 7. THORP CLAUDIO 1. DiPAOLO STEPHANIE L. HERSPERGER HUGH P. O'NEILL, III W. DARREN POWELL DRUMMOND B. TAYLOR OFCOUNSEL JAME$ K. THOMAS October 26, 2001 VIA CERTIFIED MAIL Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 RE: Doyle v. Strong Dear Ms. Doyle: Enclosed is a Rule to File a Complaint in this matter. Please respond accordingly. Thank you. Yours very truly, TH06NAS, THOMAS &HAFER, LLP By: Jeffrey B. Rettig JBR/ees Enc{osure ~ LEHIGH VALLEY OFFICE: 3400 BATH PIKE, SUITE 201, BETHLEHEM, PA 18017 (610) 868-1675 FAX (610) 868-1702 ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ® Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to:~ p ~ ~ ~ I p ~~ ~~Wl~'~ Il/v L~C..- `{S { (o ~~-abC~ed f~~ I ~ `1 0 ~ a LV d 3 -~,; C. Signatu ~~/// ~ - / v ,---~ .~~, / ~ .d,Tn r ~ '; 6J O Agent D. Is dElivery address iffere fron)•.1tem 1? U Yes If VES, enter de ery a ress below: ^ No 3. S ice Type ertKietl Mail ^ Express Mail [[[[[[~~~]]] Registered ^ Return Receipi for Merohandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (EMra Fee) ^ Yes 2. Article Number !~ p~ p,. ~ ( '+f liransfer from service label) '~ 13 V ~ ~ r. `[ O ©O~ ~ ~' C M~~ Domestic Return Receipt 3~~ 102595-dt-M-1424` THOMAS, THOMAS &HAFER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, Plaintiff Defendant c, ~= r - _: -- ~ _ f ~ Y~ cr_f <_. ~~: - _a rr y°c .. _> ~ cx+ '" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA N0. 01-5373 CIVIL ACTION -LAW PRAECIPE FOR RULE TO FILE COMPLAINT v. ANDREW CHARLES STRONG, TO THE PROTHONOTARY: Kindly issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days of service of said Rule, or suffer a judgment of non pros pursuant to Pa.R.C.P. 1037(a). THOMAS, THOMAS &HAFER, LLP ..-F, ~ ....-~.~ ~ '~f ' ~ Jeffs~° 'B. Rettig, Esqui DATE: I C~/ ~~ 0 ( Co~isel for Defendant c RULE TO FILE COMPLAINT NOW, ~-I-~_~n _2~ , 2001, RULE ISSUED AS ABOVE. THOMAS, THOMAS & HAFER, LLP By: Jeffrey B. Rettig, Esquire Identification No. 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. NO. 01-5373 ANDREW CHARLES STRONG, CIVIL ACTION -LAW Defendant NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF JUDGMENT OF NON PROS AND NOW, comes Andrew Charles Strong, by and through his attorneys, Thomas, Thomas & Hafer, LLP, to notify Plaintiff of his intention to file a Praecipe for Entry of Judgment of Non Pros in ten (10) days and state as follows: 1. This case was initiated by filing a Writ of Summons by Plaintiff on or about September 14, 2001. 2. A Rule to File a Complaint was obtained and served upon Plaintiff on October 26, 2001. 3. Plaintiff has not yet filed a Complaint and more than twenty days has elapsed since the service of the Rule to File a Complaint. 4. This Notice of Intention to File a Praecipe for Entry of Judgment of Non Pros is being served on Plaintiff as indicated on the Certificate of Service and permits Plaintiff ten days in which to cure her failure to file a Complaint. If a Complaint is not filed within the next ten days, a Praecipe for Entry of Judgment of Non Pros will be filed with the court and the case will be dismissed. THOMAS, THOMAS & HAFER, LLP i By: ~ . .~' ! ffrey B. Rettig, quire Date: ~(`~//~ f .;. .. i ~~:~.~ . ~y::: CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 THOMAS, THOMAS & HAFER, LLP Je y B. Rettig, Es ire Date: j ( ~,,r~~ l CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 Date:~~~® ~~~ THOMAS, THOMAS & HAFER, LLP 'T'om ~« ~g ,. ~ °~ ~ w 1~ ('~ ~ ~ r- THOMAS, THOMAS & HAFER, LLP By; Jeffrey 8. Rettig, Esquire Identification No. i96i6 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 Attorney for Defendant LORI COGLEY DOYLE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff v. NO. 01-5373 ANDREW CHARLES STRONG, Defendant CIVIL ACTION -LAW NOTICE OF ENTRY OF JUDGMENT OF NON PROS TO: Lori Cogley Doyle 4516 Crooked Hill Road Harrisburg, PA 17110 Jeffrey B. Rettig, Esquire P.O. Box 999 Harrisburg, PA 17108-0999 Please be advised that a judgment of norr pros has been entered against Plaintiff and in favor of the Defendant Andrew Charles Strong in the above matter. Prothonotary ~- ,?.- Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY r COGLEY DOYLE Vs. , NO. 015373 STRONG , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 12/13/01 File #: M281290 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 717-255-7237 ATTORNEY FOR DEFENDANT IHQIIIRIBS SHOIILD 88 ADDR8S58D TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3581 By: Mercedes Feeney a- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COGLEY DOYLE Vs. STRONG ~ No. 015373 TO: LORI COGLEY DOYLE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 11/20/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQIIIRI85 SHOIILD BS ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 By: Mercedes Feeney Enc(s): Copy of subpoena(s) Counsel return card File #: M281290 CONY~NWFIILTH OF PENNSYLVANIA OJiJNPY OF LU~IATID LORI COGLEY DOYLE VS. ANDREW CHARLES STRONG File No. 2001 5373 SUBPOENA TO PRODl1CE DOCtJhENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE A009.22 TO: (Name of Person or Entity Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **SEE ATTACHED ADDENDUM** at ___jg~Irnr. r FnAr RF'PRODTTCTIOD7S INC _4 49 0 DISSTON ST PHILA PA 19135 ____.__ (Address) c You may deliver or'mail legible copies of the documents a^,produce things requested ti~ this subpoena, together with the certificate. of scripliance, tq the=party: making this request at the address .listed above. You have the right to seek in advance the rea.onabla 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 'thir, subpoena may seek a court orde-~ crnpelling you to comply with it. THIS SUBP~NA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAhE: Tvc~o s~v n~mmTn ~qn ADDRESS: 3 0 5 N FRONT- TS~S01Y~55" TTTtT (~D1TT)/"~ TfT '~ `]~ TELEPHONE: 1215) 335-3212 SUPREME OOUF2T I D # ATTORNEY FOR: DEFENDANT 12113!01 DATE : ~ "aL ~UU Seal of the bourt BY THE COURT: Prothonotary k,.Civi1 Division ~~ _ '' Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA COGLEY DOYLE Vs. No. 015373 STRONG CUSTODIAN OF RECORDS FOR: DR MATTHEW BOLAND **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: LORI COGLEY DOYLE ADDRESS: DATE OF BIRTH: 05/26/58 SSAN: 195503814 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHEDHERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTSAVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) %-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or DR MATTHEW BOLAND CUMBERLAND M281290-01 *** SIG-~I AND RETURN THIS PAGE *** ~ R LE ROD Main Office Phoae: (215) 335-3212 Jefferson Bldg., Suite 926 4940 Disston Street Fax: (215) 338-2980 1015 Chestnut Street Philadelphia, Pa. 19135 E-mail Address: legal@medleg.com Philadelphia, Pa. 19107 ADDENDUM COMPLETE COPES OF ANY AND ALL RECORDS IN MEDICAL FILE, INCLUDING BUT NOT LIMT_TED T0, ANY AND ALL I2E~ORDS, CORRESPONDENCE, FILES AND MEMORANDUMS, PROGRESS NOTES, CLINIC NOTES, INPATIENT AND/OR OUTPATIENT RECORDS, RADIOLOGICAL REPORTS, HANDWRITTEN NOTES, BILLING AND PAYMENT RECORDS RELATING TO ANY EXAMINATION, INPATIENT AND/OR OUTPATIENT CONSULTATION, CARE OR TREATEMENT, ETC. w n C. ~;- T'1 ~'" ._ i ~~;_ c= r~: --, =~ - °- ~_ .. -~ v ..~ « 5? k~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DOYLE Vs. , NO. 015373 STRONG , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be se rved is identical to the subpoena(s) which is attache d to the Notice of Intent to Serve the Subpoena(s). Date: 12/20/01 File #: M281536 JEFFREY B RETTIG, ESQUIRE 305 N FRONT ST 6TH FL PO BOX 999 HARRISBURG, PA 17108 717-237-7101 ATTORNEY FOR DEFENDANT INQIIIRIES SHOIILD B8 ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3581 By: Nercedes Feeney IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY DOYLE Vs. STRONG ~ No. 015373 TO: LORI COGLEY DOYLE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 11/29/01 JEFFREY B RETTIG, ESQUIRE 305 N FRONT ST 6TH FL PO BOX 999 HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQIIIRIES SBOIILD B8 ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 By: Mercedes Feeaey Enc(s): Copy of subpoena(s) Counsel return card File #~ M281536 OO2MfONWF.9LTH OE' PENNSYLVANIA COUN'I^l OF C(3H~IALID DOYLE . Vs. File No. 015373 STRONG REQUESTED TRAVELERS PROP & CAS CO, PO BOX 13485, READING PA 19612-3485 70: (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 AT -- at MEDICAL LEGAL '(A~~ss7940 DISSTON ST., PHILA., You may deliver or mail legible copies of the documents or produce things requested ~> this subpoena, ,together with the certificate of . ccnipliance, to the party making thi= request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty l20) days after its service, the party serving 'thin subpoena may seek a court orde-- ccxTpelling you to camly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLUVIING PERSON: NAt~: JEFFREY B RETTIG, ESQ ADDRESS:- ~~~~,R~~~T.6TH FL TELEPHONE: HARRIS IFS-FA 17108 Si1PREhE COURT ID ~ 215-335-3212 ATTORNEY FOR: 19616 DEFENDANT M281536-O1 12 //.0/O1 ~ .. DATE: ' Seal of the Court BY T//HE COURTD: ,(///~ `~\JP~rothonotary O1 k, Civil Division -~~ Deputy (Eff. 7/91) ADDENDUM TO S UBPOENA DOYLE Vs STRONG No. 015373 CUSTODIAN OF RECORDS FoR: TRAVELERS PROP & CAS CO **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: LORI COGLEY DOYLE ADDRESS: DATE OF BIRTH: 05/26/58 SSAN: 195503814 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS AREATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ l NODOCIIMENTSAVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature for TRAVELERS PROP & CAS CO CUMBERLAND M281536-01 * * * SIGN AND RETURN THIS PAGE * * * M ~ R ~ICAL LE( Main Oflice 4940 Disston Street Philadelphia, Pa. 19135 ADDENDUM Phone: (215) 335-3212 Jefferson Bldg., Suite 926 Fax: (215) 338.2980 1015 Chestnut Street E-mail Address: legal@med[eg.com Philadelphla, Pa. 19107 LORI COGLEY DOYLE'S FIRST PARTY FILE INCLUDING BUT NOT LIMITED TO ANY AND ALL POLICIES, REFLECTING THE TORT SELECTION, ALL RECORDS, MEDICAL .RECORDS AND REPORTS, CORRESPOIV'DENCE, BILLING AND PAYMENT RECORDS, INVESTIGATION REPORTS, STATEMENTS, PHOTOGRAPHS, SURVIELLANCE FOOTAGE, RESULTS OF ANY PEER REVIEW ORGANIZATION, RESULTS OF ANY INDEPENDENT MEDICAL EXAMINATION, FILE HANDER LOG NOTES, RESULTS OF ANY INDEX CHECKS, ETC. CLAIM/FILE #278 PP S3B 8769M. OOtM~NWEALTH OF PIIaLSYLVANIA ODUNTY OF C[1N11?EE2I,ALID DOYLE Vs. STRONG File No. 015373 SUBPOENA TO PRODUCE DOCUMENTS OR THINl3S FOR DISOOVERY PURSUANT TO RULE 4009.22 TRAVELERS PROP & CAS CO, PO BOX 13485, READING PA 19612-3485 TO: nTTDd• L1PmFRWRTTTNC. rIFPT (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 ATT ~ DE -- at MBDICAL LEGAL RSPRODIICTIONS~As~940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested ty 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 (20) days after its service, the party cxrrpelling you to comply with it. things required by this subpoena within twenty serving thin, subpoena may seek a court orde~- THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCAVING PERSON: NAME: .TFFFRF~~RETTIG, ESQ ADDRESS' --~ 6TH FL TELEPHONE: HARRISBURG, PA 17108 SUPREME COURT ID .~ 215-335-3212 ATTORNEY FOR: 19616 DEFENDANT M281536-02 12/% 0/O1 DATE: Seal of the Court BY TF-E COURT: Prothonotary/~1 k, Civil Division Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA DOYLE Vs. No. 015373 STRONG CUSTODIAN OF RECORDS FoR: TRAVELERS PROP & CAS CO LORI COGLEY'S UNDERWRITING FILE. CLAIM/FILE #278 PPS 3B8769M PERTAINING TO: NAME: LORI COGLEY DOYLE ADDRESS: DATE OF BIRTH: 05/26/58 SSAN: 195503814 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTSAVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or TRAVELERS PROP & CAS CO CUMBERLAND M281536~02 * * * SIGN AND RETURN THIS PAGE * * c -n ~' , '''T ~ s.t~ xil a ~ ~ ~ m s =° .c- .~