HomeMy WebLinkAbout01-06918
JOHN P. aLO and JANICE L. ILLO,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2001- (, 'tIt CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS
TO CURTIS R. LONG, PROTHONOTARY:
Please issue a Writ of Summons against the defendant, John Rosenberry, and enter my appearance on
behalf of the plaintiffs, John P. IIIo and Janice L. IIIo. Please direct the Sheriff to serve the defendant as follows:
Mr. John Rosenberry
1000 Mayapple Drive
Shippensburg, P A 17257
Respectfully submitted,
By:
December 6, 200 I
To: JOHN ROSENBERRY
You are hereby notified that John P. D10 and Janice L. D1o, his wife, plaintiffs, has commenced an action
against you which you are required to defend or a default judgment may be entered against you.
('", To" tP. P!"T~O;ARY
By:
r/.A.L O. In,((), ~
f DEPUTY
Date:~ 7 ,2001
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JOHN P. ILLO and JANICE L. ILLO,
PLAINTIFFS
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2001-6918 CIVIL TERM
JOHN ROSENBERRY,
DEFENDANT
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,
l'
By:
Andrew C. Lehman, Esquire---
Atty. !.D. #8l937
2411 North Front Street
Harrisburg, P A 1711 0
(717) 232-9900
Date: 12/26/01
RULE
TO THE PLAINTIFFS:
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: 1:1. /:;1/01
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JOHN P. ILLO and JANICE L. ILLO,
PLAINTIFFS
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2001-6918 CIVIL TERM
JOHN ROSENllERRY,
DEFENDANT
JURY TRIAL DEMANDED
PRAECIPE
TO THE PROTHONOTARY:
Please enter the undersigned's appearance on behalf of the Defendant, John Rosenberry,
regarding the above-captioned matter.
Respectfully submitted,
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By: .
Andrew C: Lehman, Esquire
Atty. !.D. #81937
2411 North Front Street
Harrisburg, PA l7110
(717) 232-9900
Date: 12/26/0 1
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CERTIFICATE OF SERVICE
AND NOW, this 26th day of December, 200l, I hereby certify that I have served the
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foregoing Praecipe on the following by depositing a true and correct copy of same in the United
States mails, postage prepaid, addressed to:
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Marcus A. McKnight, III, Esquire
60 West Pomfret Street
Carlisle, P A l7013
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JOHN P. ILLO and
JANICE L. ILLO,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2001-6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
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 within twenty (20) days after this complaint, order and
notice are served, by entering a written appearance personally or by attomey 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 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, Peunsylvania 17013
(717) 249-3166
1-800-990-9108
Americans with Disabilities
Act of 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the
court. You must attend the scheduled conference or hearing.
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JOHN P. ILLO and
JANICE L. ILLO,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2001-6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
COMPLAINT
AND NOW, this ~y of January 2002 come the plaintiff, John P. Illo and Janice L.
Illo, by and through their attorneys, Irwin, McKnight & Hughes, and makes the following
Complaint against the defendant, John Rosenberry:
1.
The plaintiffs are John P. Illo and Janice L. Illo, adult individuals residing at P. O. Box
55, Shippensburg, Pennsylvania 17257.
2.
The defendant is Mr. John Rosenberry, an adult individual residing at 1000 Mayapple
Drive, Shippensburg, Pennsylvania, 17257.
3.
On December lO, 1999, the plaintiff was attempting to step off the curb in an effort to
cross King Street in Shippensburg, Pennsylvania.
4.
Without warning, a vehicle operated by defendant, John Rosenberry, moved rapidly in
reverse while attempting to exit his parking space and struck the plaintiff.
2
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5.
The impact of the vehicle caused numerous injuries to the plaintiff left hip, leg, knee and
left wrist.
6.
The injuries sustained by the plaintiff was caused by the negligence and careless actions
of the defendant, John Rosenberry.
7.
The defendant, John Rosenberry, was negligent and careless as follows:
a, He failed to maintain his vehicle under proper control in an effort
to avoid injuring a pedestrian;
b. He failed to properly look in all directions in order to determine
if the area was clear to move from his parking space onto King Street;
c, He failed to provide any warning of his intention to move from
the parking space onto King Street; and
d. He was operating his vehicle at an unsafe speed as he backed his vehicle.
8.
The negligent actions ofthe defendant, John Rosenberry, were the proximate cause ofthe
injuries to the plaintiff, John P. Illo.
9.
The plaintiff, John P. Illo, seeks compensation for the pain and suffering, emotional
distress, embarrassment and loss of life's pleasures since the date of the accident as well as
compensation for future losses he will incur in these areas.
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10.
The plaintiff, John P. Illo, seeks compensation for the medical expenses which he has
incurred and may incur in the future to treat his injuries.
11.
The plaintiff, John P. Illo, seeks compensation for the serious and permanent injuries
which he has sustained which has required surgery and may require additional further surgery or
therapy.
12.
The plaintiff, Janice L. Illo, seeks compensation for the loss of companionship and
society as a consequence of the injuries sustained by her husband, John P. Illo,
WHEREFORE, the plaintiffs, John P. Illo and Janice L. Illo, request compensation and
damages from the defendant, John Rosenberry, in the amount in excess of Twenty-Five
Thousand and no/100 ($25,000.00) Dollars with interest as permitted by law and the costs of this
litigation.
By:
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Date: January 17,2002
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VERIFICATION
The foregoing document is based upon information which has been gathered by
counsel and myself in the preparation of this action. I have head the statements rnade in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of l8 Pac C.S.A. Section
4904, relating to unsworn falsification to authorities.
Date: January 17, 2002
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JOHN P. ILLO and
JANICE L. ILLO,
Plaintiffs
v.
2001-6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Marcus A, McKnight, III, Esquire, hereby certifY that a copy of attached Complaint
was served upon the following by depositing a true and correct copy of the same in the United
States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below
and addressed as follows:
Andrew C. Lehman, Esquire
NEALON AND GOVER, P.C.
2411 North Front Street
Harrisburg, PA 17110
IRWIN, McKNIGHT & HUGHES
By:
Date: January 18, 2002
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IN THE COURT OF COMftJlON PLEAS
CUMBERLAND COUNTY, PENNA.
NO. 2001-6918 CIVIL TE~M
JOHN P. ILLO AND JANICE L. ILLO,
Plaintiffs,
JOHN ROSENBERRY,
Defendant.
JURY TRIAL DEMANDEIl>
NOTICE TO PLEAD
TO: John P. and Janice L. 1110, and their attorney,
Marcus A. McKnight, III, Esquire
IRWIN, McKNIGHT & HUGHES
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013-3222
YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein
contains averments against you to which you are required to respond within twenty (20)
days after service thereof. Failure by you to do so may constitute an admission.
Respectfully submitted,
NEALON & GOVER, P.C.
Date:
~ 0 c;;.----
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BY~~
Andrew C. Lehman, Esquire
1.0. #: 81937
2411 North Front Street
Harrisburg, PA 17110
717/232-9900
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JOHN P. ILLO AND JANICE LILLO,
Plaintiffs,
IN THE COURT OF COMI\IION PLEAS
CUMBERLAND COUNTY, PENNA
v.
NO, 2001-6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant.
JURY TRIAL DEMANDEID
ANSWER WITH NEW MATTER
1. Admitted upon information and belief.
2, Admitted.
3.-4. Denied as stated. However, it is admitted that December 10, 1999, as
Defendant was attempting to pull out from his parking spot along the curb of King Street
in Shippensburg, Pennsylvania, the rear of his 1998 Saturn SL came into contact with
Plaintiff John P. 1110'S person. The remaining averments contained in these paragraphs
are denied pursuant to Pa.R.C.P. 1029(e).
5. Denied as Defendant is without sufficient information to form a belief as to
the truth of the matter asserted and proof is demanded at trial. Any remaining
averments contained in this paragraph are strictly denied pursuant to
Pa.R.C.P.1029(e).
6.-8. Denied pursuant to Pa.R.C.P. 1029(e). To the extent further factual
averments are contained in these paragraphs, they are denied as Defendant is without
sufficient information to form a belief as to the truth of the matter asserted, and proof is
demanded at trial.
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9.-11. No response is required. However, to the extent a response is deemed
required, all averments contained in these paragraphs are denied pursuant to
Pa.R.C.P. 1029(e). Furthermore, any remaining averments contained in these
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paragraphs are denied as Defendant is without sufficient information to form a belief as
to the truth of the matter asserted, and proof is demanded at trial.
12. No response is required. However, to the extent a response is deemed
required, Defendant denies any averments contained in this paragraph pursuant to
PaRC.P. 1029(e). Any remaining averments contained in this paragraph are denied
as Defendant is without sufficient information to form a belief as to the truth of the
matter asserted, and proof is demanded at trial.
NEW MATTER
13. Defendant incorporates by reference Paragraphs 1 throu~lh 12 as if set
forth fully herein by reference thereto.
14. Plaintiff John P. 1110 was contributorily negligent.
15. Plaintiff John P. IlIo's claim may be barred in whole or in part by
application of the Pennsylvania Motor Vehicle Financial Responsibility Act.
WHEREFORE, Defendant, John Rosenberry, respectfully requests that the
Complaint be dismissed with costs of this action.
Respectfully submitted,
NEALON & GOVER, P.C.
By:
Date:
/- SO-O~
Andrew C. Lehman, Esquire
1.0.#: 81937
2411 North Front Street
Harrisburg, PA 17110
717/232-9900
2
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VERIFICATION
I, JOHN ROSENBERRY, 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. S4904 relating to
unsworn falsification to authorities.
Date: I'dq-O~
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CERTIFICATE OF SERVICE
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AND NOW, this 'Jo day of
certify that I have served the foregoing ANS
, 2002, I hereby
W MAHER on the following
by depositing a true and correct copy of same in the United States mail, postage
prepaid, addressed to:
Marcus A. McKnight, III, Esquire
IRWIN, McKNIGHT & HUGHES
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013
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Andrew C. Lehman, Esquire
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SHERIFF'S RETURN - OUT OF COUNTY
, ~~?B NO: 2001-06918 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ILLO JOHN P ET AL
VS
ROSENBERRY JOHN
R, Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
ROSENBERRY JOHN
but was unable to locate Him
in his bailiwick, He therefore
deputized the sheriff of FRANKLIN
County, Pennsylvania, to
serve the within WRIT OF SUMMONS
On January
22nd , 2002 , this office was in receipt of the
attached return from FRANKLIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Franklin Co
So
~
18,00
9.00
10.00
24.00
.00
61.00
01/22/2002
IRWIN MCKNIGHT
~'7':. _
Thomas K lne
Sheriff of Cumberland
'-
County
HUGHES
Sworn and subscribed to before me
this 3o~ day Of~
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-. IiI "The Court of Common Pleas of Cumberland CountY, Pennsylvania
John P. 1110 et al
VS,
John Rosenberry
SERVE: John Rosenberry
No,
01
6918 civil
Now, Decert1ber 11
, 20~, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Franklin
County to exe:cute this Writ, this
deputation being made at the request and risk of the Plaintiff,
,;.~-"'~
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Sheriff of Cum berland County, P A
Affidavit of Service
Now,-DeCfl/Y\b.tf 19 ,20Q.Lat /'./5 o'cIock-le.....M. served the
within Pro.e.. lUr'I+-1lf SmY\tY\(W\'S (\5l'1d rUr'J of SW1\TV\()n<;
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upon
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copy of the original frne, ~~tJ~lrnw)l'\hS ~
'r 0 Sw\'Imol'lS
the contents thereof.
a
and made known to
So answers,
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Depu.-\y Sheriff of. rMkl In
1 c.,u~ A 1'1':)' if) II \
COUllty, PA
ubscribed before
day ,~()J\Il(\r\J, 20il:L
, I
COSTS
SERVICE -J<J, 00
MILEAGE
AFFIDA VIT G,. on
$
, . . ISeal
Patncla A. Strine, Notary Public
r.hflmbers~urg Rnro Franklin County
My l"":01"II''l''''l1lssion ExtJJres Nov. 4, 2004
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SHERIFF'S RETU~N - REGULAR
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CA,SE NO: 2001-69180 T
Amended
COMMONWEALTH OF PENNSYLVANIA:
.JOHN P ILLO ET AL
vS
.JOHN ROSENBERRY
GUS ALEXIOU - DEPUTY , Deputy Sheriff of FRAN4IN
County, Pennsylvania, who being duly sworn according to!law,
I
says, the within PRAE WRIT SUMMONS was served uton
I
ROSENBERRY JOHN I the
DEFENDANT , at 1315:00 Hour, on the 19th day of ~~ember , 2001
at FRANKLIN CO SHERIFF'S OFFICE 157 LINCOLN WAY EAST I
I
CHAMBERSBURG, PA 17201 by handing to !
(fOHN ROSENBERRY
t1gether with
a true and attested copy of PRAE WRIT SUMMONS
l~ WRIT OF SUMMONS
and at the same time directing His attention to the con~ents thereof,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
9,00
9,00
6.00
,00
.00
24,00
:s~u~
01/10/2002
MARCUS A, MCKNIGHT III
Sworn and Subscribed to before
this
/0
oLH'v
day of
(me
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A,D,
" N~tarjal Seal
Ch Patricia A, i.':)trif'le., Notary Public
ambersb'lf,: q, r, Frank/I'n C
My f""fn . . .- ounty
mrSSlon t:x.plres Nov. 4, 2004
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JOHN P.ILLO and
JANICE L. ILLO,
Plaintiffs
v.
2001-6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
REPLY TO NEW MATTER
AND NOW, this llth day of February 2002 come the plaintiff, John p, Illo and Janice
1. Illo, by and through their attorneys, Irwin, McKnight & Hughes, and makes the following
Answer to New Matter:
13.
The averments offact contained in paragraph one (l) through twelve (l2) of the
Complaint are hereby incorporated by reference and made a part of this Answer,
l4,
The averments contained in paragraph fourteen (l4) are conclusions of law to which an
answer is not required. The Plaintiff did not contribute in any manner to the proximate cause of
the action of the defendant who struck the Plaintiff with severe force causing his injuries.
Paragraph fourteen (14) is therefore denied.
15.
The averments contained in paragraph fifteen (ls) of the New Matter are specifically
denied, On the contrary, the Plaintiff sustained serious personal injuries as a direct consequence
of the negligence of the Defendant.
1
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li!ITf
WHEREFORE, the plaintiffs, John p, Illo and Janice L. Illo, request compensation and
damages from the defendant, John Rosenberry, in the amount in excess of Twenty-Five
Thousand and nolI 00 ($25,000.00) Dollars with interest as permitted by law and the costs of this
litigation.
Respectfully submitted,
By:
Date: February ll, 2002
2
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VERIFICATION
The foregoing Answer to New Matter is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of l8 Pa, C,S.A. Section
4904, relating to unsworn falsificationio authorities.
JO
Date: U, I! ,2002
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Jill
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JOHN P. ILLO and
JANICE L. ILLO,
Plaintiffs
v.
2001-6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Marcus A, McKnight, III, Esquire, hereby certify that a copy of attached Reply to New
Matter was served upon the following by depositing a true and correct copy of the same in the
United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced
below and addressed as follows:
Andrew C. Lehman, Esquire
NEALON AND GOVER, P.C.
2411 North Front Street
Harrisburg, P A 17110
IRWIN, McKNIGHT & HUGHES
By: Marc s A. Me . t, III, Esquire
60 West Pomfret Street
Carlisle, PA l7013
(717) 249-2353
Supreme Court I.D. No. 25476
I
!
Date: February 25,2002
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009,22
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. 1LLO
TERM,
-VS-
CASE NO: 2'OCl-6918
JOHN ROSENBERRY
.
As a prerequisite to service of a: subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of ANDREW C. LEHMAN, ESQ.
certifies that
(1) A notice of'intent to serve the subpoena with a copy of the subpoena
attacned 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
attacned 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: 02/24/2003
~S ~n~~~
~ ~C. LEHMAN, ESQ.
Attorney for DEFENDANT
DEll-394996 20874-LOJ.
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
NOTICE OF :INTBNT TO SERVE A SUBPOENA TO PRODUCE ~S AND
THINGS FOR DISCOVERY PURSUANT TO ROLB 4009'.21
SHIPPIlNBURG HEALTH SERVICES
BRANCH CREEK PHYSICIANS
CUMBERLAND VALLEY ORTHO, ASSOC
ORTHOPAEDIC ASSOCIATIlS
CHAMBIlRSBURG HOSPITAL
STATE FARM INSURANCE COMPANY
MEDICAL RECORDS , XRAYS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS , XRAYS
MEDICAL RECORDS
INSURANCE
TO: MARCUS MCKNIGHT, IlSQUIRE
MCS on behalf of ~RIlW C. LEHMAN, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file ot 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,
DATil: 02/04/2003
MCS on behalf of
ANDREW C. LIlHMAN. IlSQ.
Attorney for DEFENDANT
CC: AllDRIllI C. T,RlIIWI, IlSQ.
- 01-545
Any questions regarding this matter, contact
THB MCS GROUP INC,
1601 MARKET STRIlET
11800
PHILADELPHIA. PA 19103
(215) 246-0900
DE02-214'163 20 a 7 4 -CO:1.
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JOHN P.ILLO AND JANICE L.ILLO
\IS
JOHN ROSENBERRY
File No. ..2.Q0] -6918
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: CUSTODIAN OF RECORDS FOR: SHIPPENSBURG HEALTH SERVICES
(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 .
at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this .ubpoena, together with the
certificate of compliance, to the party making this reque.t at the addres.li.ted above. You have the right to .eek. in
advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the document. or things required by this .ubpoena, within twenty (20) day. after it. .ervice, the party
serving this subpoena may .eek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
ANDREW C.LEHMAN. ESO.
2411 NORTH FRONT ST.
HARllT!":'RTTRf: 'PA 1711 n
TELEPHONE: 215-246-0900
SUPREME COURT ID #:
AITORNEY FOR: DEFENDANT
BY
Prothonotary/Clerk, Civil . ion
0run P ?fPa&r--
Oepu
DATE:
) 02/24/2003
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EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
SHIPPENBURG HEALTH SERVICES
46 WALNUT BOTTOM ROAD
SHIPPENSBURG, PA l7257
RE: 20874
JOHN p, ILLO
Entire medical, billing, and diagnostic fIle, including but not limited to any
and all records, correspondence to and from the consulting and/or treating
physicians, fIles, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
fIlms and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject: JOHN P. ILLO
P.O. BOX 115, NEWBURG, PA 17240
Social Security #: 148~16-6673
Date of Birth: 04-10-1926
SU10-42312220874-LOJ.
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
III THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
AS a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
ANDREW C. LEHMAN, ESQ,
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena,
MCS on behalf of
DATE: 02/24/2003
ANDREW C, LEHMAN, ESQ,
Attorney for DEFENDANT
DEll-394997 20874 -LO 2
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. 1LLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
NOTICE OF llta:.I5dT TO SBRV8 A SUBPOENA TO PRODUCE PQCDMBNTS AND
TB:INOS FOR DISCOVERY PURSUJIN'l' TO R'OLB 4009.21
SHIPPBNBURG HBALTH SBRVICBS
BRANCH CRBBK PHYSICIANS
CUMBBRLAND VALLBY ORTHO. ASSOC
ORTHOPAEDIC ASSOCIATBS
CHAMBBRSBURG HOSPITAL
STATB FARM INSURANCB COMPAIIY
MEDICAL RBCORDS & XRAYS
MEDICAL RBCORDS
MEDICAL RBCORDS
MEDICAL RBCORDS & XRAYS
MEDICAL RBCORDS
INSURANCB
TO: MARCUS MCKNIGHT, BSQUIRB
MCS on behalf of ANDREW C, LBHMAN, BSQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in Which to file of record an~ 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 expensle by completing
the attached counsel card and returning same to MCS or by cont,acting our local
MCS office.
DATB: 02/04/2003
MCS on behalf of
ANDREW C.. LBHMAJI, BSQ.
Attorney for DBPBNDANT
CC: ANDREW C. ~RRV_\R, BSQ.
- 01-545
Any questions regarding this matter, contact
THB MCS GROUP INC.
1601 MARKBT STREBT
11800
PHILADBLPHIA, PA 19103
(215) 246-0900
DB02-214763 20874 -CO:L
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~ COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JOHN P.ILLO AND JANICE L.ILLO
VS
JOHN ROSENBERRY
File No. 2001-6918
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: CUSTODIAN OF RECORDS FOR: BRANCH CREEK 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 .
at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the
certificate of com'pliance, 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:
ADDRESS:
ANDREW C.LEHMAN. ESO.
2411 NORTH FRONT ST.
HA'R'RT~'RtTRr.J 'PA 1711n
TELEPHONE: 215-246-0900
SUPREME COURT ID #:
ATIORNEY FOR: DEFENDANT
DATE:
J 02/24/2003
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EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
BRANCH CREEK PHYSICIANS
67 WEST KING STREET
SHIPPENSBURG, PA l7257
RE: 20874
JOHN p, ILLO
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: JOHN P. ILLO
P.O. BOX 115, NEWBURG, PA 17240
Social Security #: 148-16-6673
Date of Birth: 04-10-1926
SU10-42312420874-L02
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009,22
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of ANDREW C, LEHMAN, ESQ,
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 02/24/2003
ANDREW C. LEHMAN, aSQ,
Attorney for DEFENDANT
DEll-394998 20874 -LO 3
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
NOTICE OF INTBN'l' TO SERVE A SUBPOImA TO PRODUCE
TBnIGS FOR DISCOVERy l'ORSUAil'r TO RULB 4009 21
SAND
SHIPPENBURG HEALTH SERVICES
BRANCH CREEK PHYSICIANS
CUMBBRLAND VALLBY ORTHO, ASSOC
ORTHOPAEDIC ASSOCIATES
CHAMBERSBURG HOSPITAL
STATB PARM INSURANCE COMPANY
MEDICAL RECORDS , XRAYS
MEDICAL RECORDS
MEDICAL RBCORDS
MEDICAL RECORDS , XRAYS
MEDICAL RBCORDS
INSURANCE
TO: MARCUS MCIOiIGHT, ESQUIRE
MCS on behalf of ANDREN .C. LEHMAN, ESQ. intends to serte 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 objecti.on to the subpoena, If the twenty day noFce period is
waived or if no Objection is made, then the subpoena may be se ed. Complete
copies of any reproduced records may be ordered at your expens by completing
the attached counsel card and returning same to NCS or by cont.cting our local
NCS office,
DATE: 02/04/2003
MCS on b~half of
ANDREW Cj LBHMAR, ESQ.
Attorney 'for DEPENDANT
CC: ANDREW C. LBBMAR, ESQ.
- 01-545
Any questions regarding this matter, contact
THB MCS q.ROUP INC.
1601 MARtET STREET
1800
PHILADELI!HIA, PA 19103
(215) 24~-0900
DE02-21476320874-C01
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COMMONWEALTH OFPENNSYL VANIA
COUNTY OF CUMBERLAND
JOHN P.ILLO AND JANICE L.ILLO
VS
JOHN ROSENBERRY
FileNo. 2001-6'n8
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND COUNTY ORTHOPEDIC ASSOC.
(Name of Penon or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or
things: SEE ATTACHED .
at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103
(Addre..)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the
certi!icate 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 YOIl fail to produce the documents or things required by this subpoena. within twenty (20) days after its service, the party
serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
ANDREW C.LEHMAN. ESO.
2411 NORTH FRONT ST.
HAR'RT~"RTTR~I PA 1711 n
TELEPHONE: 215-246-0900
SUPREME COURT ID #:
ATTORNEY FOR: DEFENDANT
BY
Prothonotary/Clerk. Civil Ir . .
~4(7q.O P
Oeputy
DATE:
) 02/24/2003
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EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
CUMBERLAND VALLEY ORTHO. ASSOC
120 N. 7TH STREET/STE 10
CHAMBERSBURG MED. BL
CHAMBERSBURG, PA l720l
RE: 20874
JOHN P. ILLO
Entire medical fUe, 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: JOHN P. ILLO
P.O. BOX 115, NEWBURG, PA 17240
Social Security #: 148-16-6673
Date of Birth: 04-10-1926 .
SU10-423126 20874 -LO 3
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009,22
IN THE MATTER OF:
COURT 0]' COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009,22
MCS on behalf of ANDREW C, LEHMAN, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena,
MCS on behalf of
DATE: 02/24/2003
ANDREW C, LEHMAN, ESQ,
Attorney for DEFENDANT
DEll-394999 :2 0 8 74 - L 04
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
NOTICE OF .:IliT8NT TO SJm.VB A SUBPOBNA TO PRODUCEDOfOMBNTS AND
THINGS !!'OR DISCOVBRY PURSUANT TO ROLE 4009.21
SHIPPBNBURG HBALTH SBRVICBS
BRAlIICH CRBBlt PHYSICIANS
CUMBBRLAND VALLEY ORTHO, ASSOC
ORTHOPABDIC ASSOCIATBS
CHAMBERSBURG HOSPITAL
STATE FARM INSiJRANCB COMPANY
MEDICAL RBCORDS , XRAYS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS , XRAYS
MEDICAL RBCORDS
INSURANCB
, TO: MARCUS MCKNIGHT, BSQUIRE
MCS on behalf of ANDREW C. LBHMAN, BSQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is 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.
DATB: 02/04/2003
MCS on behalf of
ANDRB1I c.. LEHMAN, ESQ.
Attorney for DBPBNDANT
CC: ANDRB1I C. T.R1IIIU, BSQ.
- 01-545
Any questions regarding this matter, contact
THB MCS GROUP INC.
1601 MARICBT STREET
1800
PHILADELPHIA, PA 13103
(215) 246-0900
DE02-214763 :2 0 874 - C 0 :1.
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JOHN P.ILLO AND JANICE L.ILLO
VS
JOHN ROSENBERRY
File No. 2001-69] 8
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC ASSOC.
(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 .
at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103
(Addr.ss)
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:
ADDRESS:
ANDREW C. LEHMAN. ESO.
2411 NORTH FRONT ST.
R'A'A'RT~lUT1lr-1 'PA 1711 n
TELEPHONE: 215-246-0900
SUPREME COURT 10 #:
ATTORNEY FOR: DEFENDANT
BY
DATE:
J 02/24/2003
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(Eff. 7/'17)
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EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
ORTHOPAEDIC ASSOCIATES
1035 WAYNE AVE
CHAMBERSBURG, PA l720l
RE: 20874
JOHN P. ILLO
INCLUDING ANY AND ALL MRI'S.
Entire medical, billing, and diagnostic flIe, including but not limited to any
and all records, correspondence to and from the consulting and/or treating
physicians, flIes, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
fIlms and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject: JOHN P. ILLO
P.O. BOX 115, NEWBURG, PA 17240
Social Security #: 148-16-6673
Date of Birth: 04-10-1926
SU10-423128 20874-L04
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009,22
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-vS-
CASE NO: 2001-6918
JOHN ROSENBERRY
AS a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of ANDREW C, LEHMAN, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena. is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena w~iCh
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 02/24/2003
ANDREW C. LEHMAN, ESQ,
Attorney for DEFENDANT
DEl1-395000 20874-LOS
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.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
JOHN P. ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
NOTICE OF Im'BN'l'TO SERVE A SUBPO~ TO PRODUCE DOClJI$NTS AND
THiNGS FOR DISCOVERY PURSUA1rl' TO RULE 40.09.21
SHIPPBNBURG HEALTH SBRVICBS
BRANCH CREBK PHYSICIANS
CUMBBRLAND VALLBY ORTHO, ASSOC
ORTHOPAEDIC ASSOCIATBS
CHAMBBRSBURG HOSPITAL
STATB FARM INSURANCB COMPANY
MEDICAL RBCORDS , XRAYS
MBDICAL RBCORDS
MEDICAL RBCORDS
MEDICAL RBCORDS , XRAYS
MEDICAL RBCORDS
INSURANCB
TO: MARCUS MCKNIGHT, ESQUIRE
MCS on behalf of ANDREWC. LBHMAN, 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: 02/04/2003
NCS on behalf of
ANDREW C. LBHMAN. ESQ.
Attorney for DBFBNDANT
CC: ANDRSW C. LBJIMAN, BSQ.
- 01-545
Any questions regarding this matter, contact
THB MCS GROUP INC.
1601 MARKET STREBT
11800
PHlLADBLPHIA, PA 19103
(215) 246-0900
DE02-214763 20874 -CO ~
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COMMONWEALTH OF PENNSYl VANIA
COUNTY OF CUMBERLAND
JOHN P.ILLO AND JANICE L.ILLO
VS
JOHN ROSENBERRY
File No. -2.1")01-6918
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: CUSTODIAN OF RECORDS FOR: CHAMBERS BURG 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 . , .
at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103
(Add,.,.)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the
certificale 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 OFTIIE FOllOWING PERSON:
NAME:
ADDRESS:
ANDREW C.LEHMAN. ESO.
2411 NORTH FRONT ST.
HARRT~'RTTR~r 'PA. 1711 n
TELEPHONE: 215-246-0900
SUPREME COURT ID #:
ATIORNEY FOR: DEFENDANT
BY
DATE:
I 02/24/2003
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(Eff. 7/97)
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EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
CHAMBERSBURG HOSPITAL
112 NORTH SEVENTH ST.
CHAMBERSBURG, PA l720l
RE: 20874
JOHN P. ILLO
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 alll?atient consent or refusal of treatment, procedures, tests, and/or
medicauon, 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: JOHN P. ILLO
P.O. BOX 115, NEWBURG, PA 17240
Social Security #: 148-16-6673
Date of Birth: 04-10-1926
8U10-423130 20874-L05
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009,22
IN THE MATTER OF:
COURT 0]' COMMON PLEAS
JOHN p, ILLO & JANICE L. ILLO
TERM,
-VS-
CASE NO: 2001-6918
JOHN ROSENBERRY
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
ANDREW C, LEHMAN, ESQ,
certifies that
(1) A notice of intent to serve the subpoena with a copy 01: 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: 02/24/2003
ANDREW C. LEHMAN, ESQ.
Attorney for DEFENDANT
DEll-395001 20874-L06
j~l~?W~ _ 11.1,
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
JOHN P. ILLO & JANICE L. ILLO
-VS-
JOHN ROSENBERRY
COURT 01' COMMON PLEAS
TERM,
CASE NO: 2001-6918
NOTICE OF INTJnWTO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009 _ 21
SHIPPENBURG HEALTH SERVICES
BRANCH CREEK PHYSICIANS
CUMBERLAND VALLEY ORTHO, ASSOC
ORTHOPAEDIC ASSOCIATES
CHAMBERSBURG HOSPITAL
STATE FARM INSURANCE COMPANY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
INSURANCE
TO: MARCUS MCKNIGHT, ESQUIRE
MCS on behalf of ANDREW C, LEHMAN, ESQ. intends, to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena, If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office,
DATE: 02/04/2003
CC: ANDREW C. LBHMAN, BSQ,
MCS on bebalf of
ANDRBK C. LBHMAN, ESQ.
Attorney for DBFBNDANT
- 01-545
Any questions regarding this matter, contact
'f;~;::,-lil.",~~ ~~,,' _~,,"_, ~,,---'
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THE MCS GROUP INC.
1601 MARKBT STREET
#800
PHILADBLPHIA, PA 19103
(215) 246-0900
DE02-214763 20874 -CO 1
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
JOHN P.ILLO AND JANICE L.ILLO
VS
JOHN ROSENBERRY
. FileNo. 2001-6918
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: CUSTODIAN OF RECORDS FOR: STATE FARM INSURANCE COMPANY
(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 .
ilt MCS GROUP INC.. 1601 MAREKT ST., 1/800, PHILA.PA 19103
(Addre..)
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the
<:ertificate of compliance, to the party making this request at the address listed above. You have the right to seek, in
ildvance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party
serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
ANDREW C.LEHMAN. ESO.
2411 NORTH FRONT ST.
HARRT~"RTTRr.:.J PA 1711 n
TELEPHONE: 215-246-0900
S~PREME COURT ID #:
A TIORNEY FOR: DEFENDANT
J. 02/~4/2003
DATE: _ ~A'} (:) ~~
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Seal of the Court
(Eff. 7/CJ7)
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EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
STATE FARM INSURANCE COMPANY
P.O, BOX l4007
l690 KENNETH ROAD
YORK, PA l4007
RE: 20874
JOHN P. ILLO
Any and all insurance records and PIP fIles, including but not limited to
medical reports and/or records, claims, any and all correspondence,
dOCUIllentation supporting plaintiff's claim, payments including dates of
payments, payee and reasons for payments, including any and all such items
stored in a computer database or otherwise in electronic form, pertaining to:
Dates Requested: up to and including the present.
Subject: JOHN P. ILLO
. P.O. BOX 115, NEWBURG, PA 17240
Social ~rity #: 148-16-6673
Date of Birth: 04-10-1926
Date of Loss: 12/10/1999
8U10-423132 20874 - LO 6
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JOHN P. ILLO and
JANICE L. ILLO,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2001.6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
PRAECIPE TO SETTLE AND DISCONTINUE
To Curtis R. Long, Prothonotary:
Please mark the above-captioned case settled and discontinued and issue a Settlement
Certificate to Marcus A. McKnight, ill, Esquire, at 60 West Pomfret Street, Carlisle,
Pennsylvania 17013.
Respectfully submitted,
Marc sA
60 West P ret Street
Carlisle, Penns
(717) 249-2353
{r'Z
By:
Date: October 7,2005
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JOHN P. ILLO and
JANICE L. ILLO,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
2001-6918 CIVIL TERM
JOHN ROSENBERRY,
Defendant
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Marcus A, McKnight, III, Esquire, hereby certify that a copy of attached Praecipe to
Settle and Discontinue was served upon the following by depositing a true and correct copy of
the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the
date referenced below and addressed as follows:
Michael Smoluk, Claims Adjuster
Allstate Insurance Company
Market Claim Office
6345 Flank Drive, Ste, 1000
Harrisburg, PA 17112-2765
By:
Date: October 7,2005
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