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HomeMy WebLinkAbout99-03047r'?' ? Ar 4? rtgxS d r. 1 FQ ' f tip, ' f(!?v tl L Al, l w I M 1? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 19 4 9`.30y / Ll yr ` [E_/LJ,' Civil Action - (XX) Law ( ) Equity JURY TRIAL DEMANDED EILEEN S. KROH 232 Old York Road New Cumberland, PA 17070 Plaintiff (a) & Address(es) Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. K Writ of Summons Shall be issued and forwarded to ( )Attorney (XX)Sheriff ?. Scott Henning so lr ._319 Market Street_ _P.O. Box 1177 Signature of Attorney _Harrisburo PA 17108 J7171 238-2000 Supreme Court ID No. 3229 Name/Address/Telephone No. of Attorney Date: 5/17/99 7 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. rP othonotary ' Dater '' f ( ) Check here if reverse is used for additional information Deputy 1 PRTHON. • 55 JANICE A. SHETTER a/k/a JANICE ANNETTE SHETTER R.D.#I, Box 328 Dillsburg, PA 17019 Q r Cl) Lt_ `. J. I L!J I ? •IL ' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-03047 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KROH EILEEN S VS. SHETTER JANICE A ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: SHETTER JANICE A A/K/A JANICE ANNETTE SHETTER but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania. to serve the within WRIT OF SUMMONS On June 17th, 1999 this office was in receipt of the attached return from YORK. County, Pennsylvania. Sheriff's Costs: So answ rs: Docketing 18.00 Out of County 9.00 Y.G. .: Surcharge 8.00 omas ine, eri York County 49.76 $BTb HANDLER HENNING & ROSENBERG 06/17/1999 Sworn and subscribed to before me this /? q' day of 19 9cf A.D. C - ` LCt1/y ^I'- pM, a Ab D a ® ® G 0 0 0 0 0 0 ® 0 COUNTY OF YORK OFFICE OF THE SHERIFF s(717)7 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT, and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY COPIES. 1. PLAINTIFF/S! 2.000RTNUMBER 99-3047 C1V11 Eileen S. Kroh 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ Writ of Summons Janice A. Shetter, a/k/a Janice Annette Shetter SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Janice A. Shetter, a/k/a Janice Annette Shetter 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO., CITY, BORO, TWP., STATE AND ZIP CODE AT R.D. # 1, Box 328, Dillsburg, PA 17019=`(.3`6 6nL?rx?? Pr', 7. INDICATE SERVICE: O PERSONAL 0 PERSON IN CHARGE ?IDEPUTIZE Cumbardueund D 1ST CLASS MAIL O POSTED D OTHER NOW 5/20199 _ 19 _ 1, SHERIFF OF fdhWOUNTY1 PA do reby deputize heriff of V n rk COUNTY to execute t ake ,e? m acc rding to few. This deputation being made at the request and risk of the plaintiff.! d Cumberland ADVANCE FEE PD BY CUMBERLAND COUNTY SHERIFF r C" 07, t ??J NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN • Any deputy sheriff levying upon or attaching ahy property urkle-rwithin writ'rlta eave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of suc5eputy or thin qq;ifl to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 77 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUM 11. DA f FILED W. Scott Henning, Esq". ;, area Cumberland County Sheriff _ SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 13.1 acknowledge receipt of the writ SIGNATURE OF AUTHORIZED CLERK 14. Date Received 15. EiP.ratlor0X)0Q=e or complaint as indicated above. B. Feeser 5/26/99 6/19/99 16.HOW SERVED: PERSONAL RESIDE14CE ( ) POSTED( I POE ( J SHERIFF'S OFF ( ) OTHER ( I SEE REMARKS 17. hembv cenity and return a N T FOUND because I am unable to locate the individual. comoanv, eomoration, etc, named above. fSee remarks below,) cr.nn m vev umv mnaaun ya net ,. ., I „ i „ a , „ , .. , n. lO i i 22.REMARKS: N? NA? L NEW ADDRESS FOR JANICE SHETTER IS 100 S. LOCUST STREET, APT. 1B, SHIREMANSTOWN, PA ADDRESS ABOVE IS PARENTS ADDRESS 23. Advance Costs 24. Service Costs 25. N/F 26. W4eage 27. Postage 26. Sub Total 29. Pound 30. Notary Fee 31. Surcharge 32.Total Cos $75.00 18.00 29.76 47.76 2.00 49.76 $25.24 34, Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Can. 36. M4eage/Poslagn./N. F. 39. 7olal Costs 40. Cost Due or Refund 41.AFFIRMED and subscribed to before me this _.l. _ SO ANSWER. _ 44. S.9nulure of 47, to n?1 19 99 42. day of June Ai Signature of Yom County Sheriff 4B.D e tann15ae1 ( ! SHERIFF HOSE W LLII&M M 6/16/99 q, rL1u. i czt , . v i'oMa'',"*Iaelt+?rnTnry"PA 6. ignature of orelgn 49.Dale MY QOMMI SI N 50.1 ACKNnW1 F 1,gnmissirxt F.K ems inn. 22, 200 County Sheriff ATURE T 51. Date Recervod LJ09,1 lt3, Costs 33. Cost Due or blend OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1, WHITE • AssuNg AWhomy 2, PINK - Attorney 3. CANARY • Sheriff's Office 4. BLUE -Shend's Offcee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Action - (XX) Law l JURY TRIAL DEMANDEDty EILEEN S. KROH JANICE A. SHETTER 232 Old York Road a/k/a JANICE ANNETTE SHETTER New Cumberland, PA 17070 • R.D,,y1, Box 328 Dillsburg, PA 17019 Plaintiff(s) & Defendant(s) & Address(es) Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. K Writ of Summons Shall be issued and forwarded to ( )Alto W. Scott Henning Esquire 319 Market Street P.O. Box 1177 Harrisburg PA 17108 (717) 238-2000 Name/Address/relephone No. of Attorney Signature of Supreme Court ID No. 32298 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Date: M, Oc) 1 I Check here if reverse is used for additional information 1PRTHON.•55 TRUE COPY FROM RECORD ` in Test;mony whereof, I here unto set my hand and the seal of said Court at Cartfsfe, AL ifri i fay f 7 Pf6thonotary i 99HB-00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attornevs for Defendant EILEEN S. KROH, PLAINTIFF VS. JANICE A. SHLwrm, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-3047 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Janice A. Shetter. Respectfiilly submitted, OF f'Donald R. Dorer, Esquire Attorney for Defendant Identification No. 39126 & SABA Date: July 22 1999 I j i I 99BB-00094 LAW OFFICES OF.JACOBS & SABA 214 Senate Avenue, Suite 503 Camp gill, PA 17011 Telephone Number: (717) 731-0988 EH.EEN S. I(ROH, PLAINTIFF IN TILE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A. SHm-MR, DEFENDANT NO, 99-3047 CML TERM CML ACTION - LAW JURY TRIAL DEMANDED W. Scott Henning, Esquire Handler, Henning & Rosenberg 319 Market Street, P.O. Box 1177 Harrisburg, PA 17108 Date:_ July- duly 2- 1999 L)onald R. Dorer,-J§ Attorney for Defendant + u"'uu K. corer Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Entrv of Aooearance by regular first class mail upon: to be served I O , L:1 r e ;1 t L- „ . 1 _11IJ O. Y • M O ?Cn ?+? v U a r Q ti i v ti ry Cj ww r 99HB-00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 EILEEN S. KROH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A.SHETTER, DEFENDANT No. 99-3047 CIVIL TERM CIVIL AcrION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a RULE upon plaintiff to file a Co ithin 20 days hereof suffer the entry of a Judgment of Non Pros. Jnalld IR Dorer, EsquireDate: Sgplember 23. 1999 Attorney for Defendant RULE TO FILE COMPLAINT AND NOW, this & day of , 1999 a RULE is hereby entered upon the Plaintiff tor`file a Complaint herein within 20 days after service hereof or suffer the entry of a Judgment of Non Pros. 99BB.00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 EILEEN S. KROH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A. SHETTER, DEFENDANT No. 99-3047 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe for Rule to File Corn lain to be served by regular first class mail upon: W. Scott Henning, Esquire Handler, Henning & Rosenberg 319 Market Street, P.O. Box 1177 Harrisburg, PA 17108 Dater September 23. 1999 Donald R. Dorer, Esqui Attorney for Defendant u.IS? c7 :-? C1' y fa. CV r/r 1; . _. y M U J CF, Q C ? C ? o y 2 H ,_ 1`r r O a v V tiN ` Ci w r ' h EILEEN S. KROH, Plaintiff V. JANICE A. SHETTER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3047 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint 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 Telephone 717-249-3166 or 800-990-9108 & ROSENBERG W. Scott I.D. #32298 319 Market Street P.O. Box 1177 Harrisburg, PA 171 (717) 238-2000 Attorney for Plain, f mgh/complaints/Kroh EILEEN S. KROH, Plaintiff V. JANICE A. SHETTER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3047 CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes Plaintiff, Eileen S. Kroh, by and through her attorneys HANDLER, HENNING & ROSENBERG, by W. Scott Henning, Esquire, and brings the within Complaint against the Defendant, Janice A. Shatter, and avers as follows: 1. Plaintiff, Eileen S. Kroh, is an adult individual who currently resides at 232 Old York Road, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant, Janice A. Shatter, is an adult individual who currently resides at R.D. # 1, Box 328, Dillsburg, York County, Pennsylvania, 17019. 3. At all times material hereto, Plaintiff, Eileen S. Kroh, was the owner and operator of a 1988 Pontiac Bonneville bearing Pennsylvania Registration Number AJT- 9720. 4. At all times material hereto, Defendant, Janice A. Shatter, was the owner and operator of a 1994 Ford Thunderbird bearing Pennsylvania Registration Number APK- 1466. 5. At all times material hereto, there were no adverse weather conditions and the road surface was dry. 6. On or about June 6, 1997, at approximately 8:05 a.m., Plaintiff, Eileen S. Kroh, was traveling northbound on Bridge Street in Cumberland County, Pennsylvania, when she came to a complete stop on the roadway while she waited to make a turn into a driveway. The driveway was filled with traffic and Plaintiff had to wait before entering. 7. On or about June 6, 1997, at approximately 8:05 a.m., Defendant, Janice A. Shetter, was traveling northbound on Bridge Street, directly behind Plaintiff's vehicle, when suddenly and without warning, she slammed into the rear of Plaintiff's vehicle, pushing it forward fifteen feet. 8. Prior to the aforementioned collision, Plaintiff, Eileen S. Kroh, purchased a policy of motor vehicle insurance from Travelers Insurance Company and selected the full tort option. Said policy was in full force and effect on the date of the collision. 9. The occurrence of the aforementioned collision and the resultant injuries to Plaintiff, Eileen S. Kroh, were the direct and proximate result of the negligence of Defendant, Janice A. Shetter, generally and more specifically set forth below: (a) In failing to keep alert and maintain a proper lookout for the presence of other vehicles lawfully on the roadway; (b) In failing to maintain proper and adequate control of said vehicle in order to avoid a collision with Plaintiff's vehicle; (c) In failing to properly and adequately observe the traffic conditions then and there existing; (d) In failing to be reasonably vigilant to observe Plaintiff's vehicle; 2 (e) In failing to operate her vehicle in such a manner so she could apply her brakes to avoid a collision with the rear of Plaintiff's vehicle; (f) In speeding and/or driving too fast for conditions; and (g) In failing to exercise reasonable care in the operation and control of said vehicle, in violation of 75 Pa.C.S.A. § 3714. 10. As a direct and proximate result of the negligdnce of the Defendant, Janice A. Shetter, Plaintiff, Eileen S. Kroh, sustained serious injuries including, but not limited to, myofascial pain syndrome of the right cervical, thoracic and scapular areas, numbness in her right hand, cervical disc disease with a small central disc protrusion at C4-5 and a bulging disc at T5-6, lightheadedness and daily headaches. 11. As a direct and proximate result of the negligence of the Defendant, Janice A. Shetter, the Plaintiff, Eileen S. Kroh, sustained serious personal injuries requiring emergency medical treatment and continuing medical treatment and physical therapy. 12. As a direct and proximate result of the negligence of the Defendant, Janice A. Shetter, the Plaintiff, Eileen S. Kroh, has been, and will in the future be, hindered from attending to her usual daily activities and duties, to her great detriment, loss, humiliation and embarrassment. 13. As a direct and proximate result of the negligence of the Defendant, Janice A. Shetter, the Plaintiff, Eileen S. Kroh, has suffered great physical pain, discomfort, humiliation and mental anguish, and will continue to endure the same for an indefinite period of time in the future, to her physical, emotional and financial detriment and loss. 3 14, As a direct and proximate result of the negligence of the Defendant, Janice A. Shelter, the Plaintiff, Eileen S. Kroh, has been compelled, in order to effect a cure for aforesaid injuries, to expend money for medical attention. Plaintiff continues to receive treatment and incur expenses for said injuries, and may continue to do so in the future, to her great detriment and loss. 15. As a direct and proximate result of the negligence of the Defendant, Janice A. Shatter, the Plaintiff, Eileen S. Kroh, has suffered a loss of life's pleasures and she will continue to suffer the same in the future, to her great detriment and loss. 16. As a direct and proximate result of the negligence of the Defendant, Janice A. Shetter, the Plaintiff, Eileen S. Kroh, sustained a loss of wages, and may continue to suffer the same in the future to her great detriment and loss. 17. Plaintiff, Eileen S. Kroh, believes, and therefore avers, that her injuries are permanent in nature. WHEREFORE, Plaintiff, Eileen S. Kroh, seeks damages from the Defendant, Janice A. Shelter, in an amount in excess of twenty-five thousand dollars ($25,000.00). Respectfully submitted, Date: HANDLER, HENNING & ROSENBERG W. Scott Henni Attorney I.D. # 319 Market Str P.O. Box 1177 17108 (717) Attorney for Plaintiff 4 VERIFICATION The undersigned hereby verifies that the statements in the foregoing COMPLAINT are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the above-named COMPLAINT is of counsel and not my own. I have read the COMPLAINT and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the COMPLAINT is that of counsel, I have relied upon my counsel in making this verification. The undersigned also understands that the statements therein are made subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn falsification to authorities. EILEEN S. KROH Date: 1 , ? 1S 1 7 C q ! iv ?a ?? $ , ? - a s,? _ ?. ?: ?<<? L ? u_ .,. a ,:.. o ?. - i i 99HB-00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 EILEEN S. KROH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A. SHETTER, DEFENDANT No. 99-3047 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANTS JANICE A. SHETTER, TO PLAINTIFF'S COMPLAINT Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5: 17. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §1029(e). WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiffs Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant. NEW MATTER 18. Paragraphs I through 17 are incorporated herein by reference, and made a part hereof as if set forth in full. 19. Plaintiffs claims are barred in whole or in part by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintift"s Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant. Respectfully submitted, Date: November 23. 1999 Attorney for Defendant Identification No. 39126 99HB-00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 EILEEN S. KROH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A.SHETTER, DEFENDANT No. 99-3047 CIVIL TERM CIVIL AcrION - LAW JURY TRIAL DEMANDED VERIFICATION DONALD R. DORER, ESQUIRE, hereby states that he is the attorney for the Defendant in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. 5 *t. O , FSQUIRE Attorney for Defendant Dated: November 23-1929 `99HB-OW94 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 EILEEN S. KROH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A. SHETTER, DEFENDANT No. 99-3047 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendant. Janice A Shetter to Plaintiffs Complaint to be served by regular first class mail upon: W. Scott Henning, Esquire Handier, Henning & Rosenberg 319 Market Street, P.O. Box 1177 Harrisburg, PA 17108 Date: November 23. 1999 Attorney for Defendant rr U_ U M in n m noon v G m „ ao G V d en ^ min 4L .:n m , e O mv)?+n rA rl U a^" N v; Ci u EILEEN S. KROH, Plaintiff V. JANICE A. SHETTER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3047 CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT. JANICE A. SHETTER AND NOW, comes Plaintiff by and through her attorneys, Handler, Henning & Rosenberg, and submits her Reply to New Matter as follows: 18. Paragraph 18 is an incorporation paragraph to which no responsive pleading is required. 19. Denied. The allegation set forth in Paragraph 19 is a conclusion of law to which no responsive pleading is required; however, to the extent that the Honorable Court deems a response necessary, the Plaintiff acknowledges that she will be bound by any reasonable and proper interpretation of the provisions of the Pennsylvania No Fault Motor Vehicle Insurance Act, and/orthe Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, the Plaintiff requests the relief as set forth in her Complaint. Respectfully submitted, HANDLER, HENNING & Date: f ! / L / By:! --T W. Attome? I.D. # 32298" 319 Ma et Str P.O. Box 7 Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiff EILEEN S. KROH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 99-3047 JANICE A. SHETTER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On the 1st day of December, 1999, 1 hereby certify that a true and correct copy of Plaintiff's Reply to New Matter of Defendant, Janice A. Shatter, was served upon the following by depositing in the United States Mail in Harrisburg, Pennsylvania: Donald R. Dorer, Esq. JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 HANDLER, HENNING & ROSENBERG Date: ?_/ _[ t squi W. Scott He S I.D. #32298 319 Market P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 ATTORNEY FOR PL INTIFF C J i:i '; C O ICJ r (1 lA- 0 71 c'v 7 U CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'P IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM -VS- CASE NO: 99-3047 JANICE A. SHETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant 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 the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/12/2000 i DONALD R. RORER. ESQUIRE Attorney for DEFENDANT DELI-1^85990 293.66-1.03. C OMMO NLTEAL T H OE;* P E N N S YLVAN =A COUNTY OP CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS [ Note: see enclosed list of locations ] TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 05/21/2000 CC: DONALD R. RORER, ESQUIRE - 99HB00094 JOEL SHUTT - 5837CS46568 Any questions regarding this matter, contact MCS on behalf of DONALD R. DORER ESQUIRE Attorney for. DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-122597 293-66-C:02- >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL MILTON S. HERSHEY MEDICAL CTR. MEDICAL HOLY SPIRIT HOSPITAL MEDICAL RICHARD N. FIDELER, M.D. MEDICAL DR. ROBERT KANEDA MEDICAL DR. E.S. VIOLAGO MEDICAL POLYCLINIC MEDICAL CENTER MEDICAL HEALTHSOUTH SPORTS MEDICINE MEDICAL FAMILY E INTERNAL MED. INSURANCE TRAVELERS INS. CO. DEOZ-122597 2 9 1 6 6- C 0 2 EILEEN S. KROH VS JANICE A. SHETTER File No. 99-3047 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL CENTER (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 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in . advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TELEPHONE (215) 246-0900 SUPRENIE COURT 1D #: _ ATTORNEY FOR: THE DEFENDANT BY THE COURT: DATE ,211.tj 14 kr y COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Praihonat?an/Clt C'il Division Deputy Seal of the Court EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL C`FR. 500 UNIVERSITY DRIVE PO BOX 850 HERSHEY, PA 17033 RE: 29166 EILEEN S. KROH Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject : EMEEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security 1f: 20946-1997 Date of Birth: 10-21-1954 IN THE MATTER OF: EILEEN S. KROH JANICE A. SHETTER CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F -VS- COURT OF COMMON PLEAS TERM, CASE NO: 99-3047 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. RORER, ESQUIRE defendant 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 the 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: 06112/2000 DONALD R. RORER, ESQUIRE Attorney for DEFENDANT DE11-185999 2-93-66-L 0 2 COMMONWEAL T H 01F P E NN S YL VAN =A COUNT 'Y' O EP CUMBERLAND iN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS [ Note: see enclosed list of locations ] TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to HCS or by contacting our local HCS office. DATE: 05121/2000 CC: DONALD R. DORER, ESQUIRE - 99HB00094 JOEL SHUTT - 5837CS46568 HCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE HCS GROUP INC. 1601 MARKET STREET /800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-122597 29166-C02 >>> LOCATION LIST <<< PACE: RECORDS REQUESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL INSURANCE HILTON S. HERSHEY MEDICAL CTR. HOLY SPIRIT HOSPITAL RICHARD W. FIDELER, H.D. DR. ROBERT KANEDA DR. E.S. VIOLAGO POLYCLINIC MEDICAL CENTER HEALTHSOUTH SPORTS MEDICINE FAMILY E INTERNAL MED. TRAVELERS INS. CO. DE02-122597 2 9 1 6 6- C O 2 f i { COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EILEEN S. KROH VS File No. 99-3047 JANICE A. SHETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Peron 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 GRO)IJP TV- 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek-, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE, SUITE 503 _ CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID .: ATTORNEY FOR THE DEFENDANT DATE ?1a ?,% BY THE COURT: " n Prothonotary/Clc C' it Divition ` /t . 1J )?91 QV?. Deputy Seal of the Court EXPLANATION OF RE, QUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL RADIOLOGY & DIAG. IMAGING N. 21ST STREET CAMP HILL, PA 17011 RE: 29166 EILEEN S. KROH Any and all records, correspondence, tiles and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and induding the present. Subject : EILEEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security h': 20946-1997 Date of Birth: 10-21-1954 sme-243730 29266-1,0Z IN THE MATTER OF: EILEEN S. KROH JANICE A. SHETTER CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F I' -VS- COURT OF COMMON PLEAS TERM, CASE NO: 99-3047 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant 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 the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/12/2000 DONALD R. DORER, ESQUIRE _ Attorney for DEFENDANT DE11-186000 293-66-3L.03 C OMMO NWEAL T H O V PENN S YL VAN =A COUNTY O IF CLIMB E KLAN D IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS [ Note: see enclosed list of locations TO: N. SCOTT HENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 05/21/2000 CC: DONALD R. DORER, ESQUIRE - 99HBOO094 JOEL SHUTT - 5837CB46568 Any questions regarding this matter, contact - MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET /800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-122597 2-93-66-C;02- >>> LOCATION LIST <<< PACE; 1 l RECORDS REQUESTED i LOCATION NAME , MEDICAL MILTON S. HERSHEY MEDICAL CTR. MEDICAL HOLY SPIRIT HOSPITAL MEDICAL RICHARD W. FIDELER, M.D. MEDICAL DR. ROBERT KANEDA MEDICAL DR. E.S. VIOLAGO MEDICAL POLYCLINIC MEDICAL CENTER l MEDICAL HEALTHSODTH SPORTS MEDICINE MEDICAL FAMILY 6 INTERNAL MED. INSURANCE TRAVELERS INS. CO. i DEOZ-122597 2 9 1 6 6- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EILEEN S. KROH VS File No. 99-3047 JANICE A. SHETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 40G9.22 TO: CUSTODIAN OF RECORDS FOR: RICHARD W. FIDELER M. D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, things: SE are ordered by the court to produce the following documents or TTACHED at MCS GROUP INC 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the p", 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: _ DONALD R. RORER ESQUIRE ADDRESS: 714 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE: _(215) 246-0900 SUPREME COURT ID =: ATTORNEY FOR THE DEFENDANT BY THE COURT: n DATE: -_ )'h, r, /Q ?2C07J ?Prn?t?hoAn_otan• Clerk, t Division Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RICHARD W. FIDELER, M.D. 56 ERFORD ROAD CAMP HILL, PA 17011 RE: 29166 EILEEN S. KROH Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : EILEEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security: 209-46-1997 Date of Bk1h: 10-21-1954 SU10-248782 29166-I,03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22-F IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM, -VS- CASE NO: 99-3047 JANICE A. SHETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER ESQUIRE defendant 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 the certificate, (3) No objection to the subpoena has been received, and W The subpoena which will. be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06112/2000 DONALD R. DORER, ESQUIRE Attorney for DEPENDANT DE11-186001 293-66-L.04 C 01 10 NWEAL T H OF P E N N S YLVAN TA COUNTY OF CUMB E KLAN D IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3041 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS [ Note: see enclosed list of locations ] TO: X. SCOTT HENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 05/21/2000 CC: DONALD R. DORER, ESQUIRE - 99HB00094 JOEL SHUTT - 5837CS46568 Any questions regarding this matter, contact MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-122597 2 9 1 6 6- C 0 2 >>> LOCATION LIST <<< PACE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL MILTON S. HERSHEY MEDICAL CTR MEDICAL . HOLY SPIRIT HOSPITAL MEDICAL RICHARD W. FI-DELER M.D. MEDICAL , DR. ROBERT KANEDA MEDICAL DR. E.S. VIOL.AGO MEDICAL POLYCLINIC MEDICAL CENTER MEDICAL HEALTHSODTH SPORTS MEDICINE MEDICAL FAMILY 6 INTERNAL MED. INSURANCE TRAVELERS INS. CO. DE02-122597 2 9 1 6 6- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EILEEN S. KROH VS File No. 99-3047 JANICE A. SHETTER FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR; DR. ROBERT KANEDA (Name of Person or Fntih•) Within twenty (20) davs after things: service of this subpoena, SF at are ordered by the court to produce the following documents or TTACHED (Address) 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 twenh• (20) davs after its service, the parrv 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: DONALD R. DORER, ESQU_ IRE ADDRE55: 21.4 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TELEPHONE: f21s) 746 0900 SUPREw1E COURT 1D ATTORNEY FOR: THE DEFENDANT DATE _ Ybt,. /P -2IVU BY THE COURT: Prothonotary/Cler '.1 Dixision Deputy Seal of the Court EXPIL A.NAIION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ROBERT KANEDA 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 29166 EILEEN S. KROH Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : EH.EEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security A 209-46-1997 Date of Birth: 10-21-1954 SU10-248784 29166-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM, -VS- CASE NO: 99-3047 JANICE A. SHETT£R As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. RORER, ESQUIRE defendant 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 an which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/12/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-186002 2-9X66-3L0.5 C OMMO NWEAI-T H OP P E N N S YL VAN TA COUNT "Y" OP C UMB E BLAND IN THE M.OTTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS ( Note: see enclosed list of locations TO. X. SCOTT HENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 05/2112000 CC: DONALD R. DORER, ESQUIRE - 99HB00094 JOEL SHUTT - 5837CB46568 Any questions regarding this matter, contact MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 22597 2 9 2.45 6 >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL INSURANCE MILTON S. HERSHEY MEDICAL CTR. HOLY SPIRIT HOSPITAL RICHARD N. FIDELER, M.U. DR. ROBERT RANEDA DR. E.S. VIOLAGO POLYCLINIC MEDICAL CENTER HEALTHSOUTH SPORTS MEDICINE FAMILY E INTERNAL MED. TRAVELERS INS. CO. DE02-122597 2 9 1 6 6- C O Z COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EILEEN S. KROH VS JANICE A. SHETTER File No. 99-3047 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. E.S. VIOLAGO (:came of Person or Entity) Within twenty (20) days after se.r ice of this subpoena, things: - SF are ordered by the court to produce the following documents or TTACHED at MCS GROUP INC, 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DONALD R RORER ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID r: _ ATTORNEY FOR THE DEFENDANT DATE: - )9_1 14 247y BY THE COURT: Prothonotary/Clerk Division Deputy Seal of the Court I IEXPI[ANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. E.S. VIOLAGO PENN REHAB ASSOC. 2601 N. 3RD ST. 1 HARRISBURG, PA 17110 i RE: 29156 EILEEN S. KROH ? Any and all records, correspondence, files and mcrtrorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. i Dates Requested: up to and including the present. Subject : EILEEN S. KROH 232 OLD FORK RD., NEW CUMBERLAND, PA 17070 Social Security #: 20946-1997 Date of Birth: 10-21-1954 i a SUIO-248786 29166-LO5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: EILEEN S. KROH COURT OF COMMON PLEAS -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant 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 the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/12/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-186003 24166-I?045 P E N N S YLVAN SA COMMONWEAL T H OE;* COUNT-'Z OE;- CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS ( Note: see enclosed list of locations TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 0512112000 CC: DONALD R. RORER, ESQUIRE - 99HB00094 JOEL SHUTT - 5837C846568 Any questions regarding this matter, contact MCS on behalf of DONALD R DORER ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 1 t. I: i DE02-122597 2 9 1 6 6- C O >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL INSURANCE HILTON S. HERSHEY MEDICAL CTR. HOLY SPIRIT HOSPITAL RICHARD W. FIDELER, H.D. DR. ROBERT KANEDA DR. E.S. VIOLAGO POLYCLINIC MEDICAL CENTER HEALTHSOUTH SPORTS MEDICINE FAMILY & INTERNAL MED. TRAVELERS INS. CO. DE02-122597 2-93-66-C:02- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EILEEN S. KROH VS File No. _ 99-3047 JANICE A. SHETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: POLYCLINIC MEDICAL CENTER (Name of Person or Entiry) 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 MCSS ?R?INC. 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) --' You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twent• (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 DONALD_ R. DORER ESQUIRE ADDRESS: 214 SENATE AVENUE. SUITE 503 CAMP HILL PA 17011 TELEPHONE (215) 246-0900 _ SUPREME COURT ID r: ATTORNEY FOR: THE DEFENDANT DATE 2Le t ?2M BY THE COURT: C.".L 4 /2 Prolhono4ry/0erf, •il ivision Qt?„ `21e Depury Seal of the Court EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: POLYCLINIC MEDICAL CENTER 2601 NORTH THIRD STREET HARRISBURG, PA 17110 RE: 29166 EILEEN S. KROH INCLUDING ANY AND ALL RECORDS FROM THE PHYSICAL THERAPY DEPT Any and all records, correspondence, riles and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject : EILEEN S. KROR 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security P 209-46-1997 Date of Birth: 10-21-1954 SUIO-268788 29156-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'P IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM, -VS- CASE N0: 99-3047 JANICE A. SHETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of _DONALD R. DORER ESQUIRE defendant 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 the 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. J I DATE: 06/12/2000 DONALD R. DORER ESQUIRE Attorney for DEFENDANT DE11-186004 Z93-66-3L.07 COMMONWEALTH OE;' P E NN S YL VAN 2A COUNTY OP CTJMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TBRM, CASE NO: 99-3047 NOTICE. OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS ( Note: see enclosed list of locations ] TO: W. SCOTT HENNING, ESQUIRE HCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 05/21/2000 CC: DONALD R. DORER, ESQUIRE - 99BB00094 JOEL SHUTT - 5837C846568 Any questions regarding this matter, contact MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE HCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-122597 2-93-66-002: I >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED LOCATION NAME MEDICAL MILTON S. HERSHEY MEDICAL CTR. MEDICAL HOLY SPIRIT HOSPITAL MEDICAL RICHARD.W. FIDELER, M.D. MEDICAL DR. ROBERT KANEDA MEDICAL DR. E.S. VIOLAGO MEDICAL POLYCLINIC MEDICAL CENTER MEDICAL HEALTHSOUTH SPORTS MEDICINE MEDICAL FAMILY Ft INTERNAL MED. INSURANCE TRAVELERS INS. CO. i l DE0Z-122597 2 9 1 6 6- C O 2 COMMONWEALTH OF PENNSYLVANIA_ COUNTY OF CUMBERLAND EILEEN S. KROH VS ' File No. 99-3047 JANICE A. SHETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR; HEALTHSOUTH SPORTS MEDICINE - (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: -- IFF ATTA HFD at MCS GROUP INC. 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the part 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 twenh, (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 DONALD R. DORER. ESQUIRE ADDRESS: 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TELEPHONE _ (215) 246-0900 SUPREME COURT ID _ ATTORNEY FOR THE DEFENDANT DATE Yl ? /E ;4t BY THE COURT- (-". T. &.4 1 . Proth?ury/Cle 11 Division Deputy Seal of the Court EXPL.ANNFION OF REQUIRED RECORDS TO: CUS'T'ODIAN Of RECORDS FOR: HEAL111SOLPI'll SI'OIt7S MEDICINE 450 POWERS AVENUE SUI'TE' 102 HARRISBURG, PA 17109 RE: 29166 EILEEN S. KROH Any and all records, correspondence, riles and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : EILF.EN S. I{R013 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security h: 209-46-1997 Date of Birth: 10-21-1954 SII2n-2tOi°t! .2°2?t5-TsQ?-: . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM, -VS- CASE NO: 99-3047 JANICE A. SHETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant 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 the 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. BATE: 06/12(2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT, COMMONWEALTH. O E7 P E NN S YL VAN 2A COUNTY O E7 CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 NOTICE ON INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS ( Note: see enclosed list of locations ] TOt W. SCOTT KENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena nuty be nerved pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 05/2112000 CC: DONALD R. DORER, ESQUIRE - 99HD00094 JOEL SHUTT - 5837C846568 MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-122597 2-93.156-C07- MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL INSURANCE >>> LOCATION LIST <<< PAGE: I LOCA MILTON S. HERSHEY MEDICAL CTR. HOLY SPIRIT HOSPITAL RICHARD W. FIDELER, H.D. DR. ROBERT KANEDA DR. E.S. VIOLAGO POLYCLINIC MEDICAL CENTER HEALTHSOUTH SPORTS MEDICINE FAMILY 6 INTERNAL MED. TRAVELERS INS. CO. DE02-1.22597 2 9 1 6 6- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EILEEN S. KROH VS File No. 99-3047 JANICE A. SHETTER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: FAMILY & INTERNAL MEDICINE (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 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the part 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 pan 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: DONALD R. DORER. ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE (215) 246-0900 SUPRENIE COURT ID r: ATTORNEY FOR: THE DEFENDANT DATE '2'"v BY THE COURT: Prothonotan•/?C,lerk?iviVpivifion Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FAMILY & INTERNAL MED. 857 S. ARLINGTON AVE. HARRISBURG, PA 17109 RE: 29166 EILEEN S. KROH Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present Subject : ME N S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security #!: 209-46-1997 Date of Birth: 10-21-1954 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE HATTER OF: EILEEN S. EROH -VS- COURT OF COMMON PLEAS TERM, CASE NO: 99-3047 JANICE A. SHETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant 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 the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/12/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-186006 2-9:L(545-T,09 COMMOD WEALTH Or-' PIENNSYLV.A.NTA CO"UNT"Y' OF' CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS [ Note: see enclosed list of locations] TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 05/2112000 CC: DONALD R. DOPER, ESQUIRE - 99HB00094 JOEL SHUTT - 5837C846568 Any questions regarding this matter, contact MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-122597 2-93-66-C02- >>> LOCATION LIST <<< PAGE; 1 RECORDS REQUESTED LOCATION NAME i MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL INSURANCE MILTON S. HERSHEY MEDICAL CTR.. HOLY SPIRIT HOSPITAL RICHARD V. FIDELER, M.D. DR. ROBERT KANEDA DR. E.S. VIOLAGO POLYCLINIC MEDICAL CENTER HEALTHSODTH SPORTS MEDICINE FAMILY 6 INTERNAL MED. TRAVELERS INS. CO. DE02-122597 2 9 1 6 6- 0 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EILEEN S. KROH VS JANICE A. SHETTER File No. 99-3047 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: TRAVELERS 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: EE AITACHED at MCS GROUP INC. 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the parry 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 OFTHE FOLLOWING PERSON: NAME: DONALD R DORER ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE 215 246-0900 SUPREME COURT ID r: ATTORNEY FOR: THE DFFFND NT BY THE COURT: _ r ;? . DATE 111,4 207t) Prothonotary 10c" d t oi?;.;an Depury Seal of the Court EXPLANATION OF RE, QUIRE' D RECORDS TO: CUSTODIAN OF RECORDS FOR: TRAVELERS INS. CO. 505 OLD RITTER RD. MECHANICSBURG, PA 17055 RE: 29166 EILEEN S. KROH CLAIM NO. SHZ955SR DATE OF LOSS: 6-6-97 Any and all claims files. Dates Requested: up to and including the present. Subject : EILEEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security A 209-46-1997 Date of Birth: 10-21-1954 Date of Loss: 06/06/1997 SU10-248794 7-93-456-r,09 J i i 1 ? h u `1 CJ ti L;':.; 7 LI J:_ File No.: 99HB-OW94 (Must be typewritten and submitted in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court. ( ) for trial without a jury. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) Eileen S. Kroh, Plaintiff Janice A. Shelter, Vs. Defendant (Check One) ( ) Assumpsit ( ) Trespass ( x ) Trespass (Motor Vehicle) The trial list will be called on April 3. 2001 Trials commence on _Arr1130, 2001 Pre-trials will be held on April 11. 2001 (Briefs am due 5 days before pre trials.) (rho party listing this use for trial shall provide forthwith a copy of the pnec one to all counsel, pursuant to local Rule 2141.) No. 99-3047 Civil 1992_ .Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dore r. Fsguire. Attorney for Defendant: Jacobs & Saba 214 Sgnate Avenue Suite 503 Camp Hill Pennsylvania 17011 • (717) 731-0988 Indicate trial counsel for other parties if known: W. Scott Henning. Esquire. Attorney for Plaintiff: Handler. This case is ready for trial. Print (Other) Attorney for: Defendant, Janice A. Shelter Date: January 30. 2001 99BB-00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant EILEEN S. KROH, PLAINTIFF VS. JANICE A. SHETTER9 DEFENDANT IN THE COURT OF COMMON PLEAS fl CUMBERLAND COUNTY, PENNSYLVANIA No. 99-3047 CIVIL TERM CIVIL ACTION-LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praeci a for Listin to be served by regular first class mail upon: Case for Trial W. Scott Henning, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Date: January 30, 2001 f V/ on . Dorer, Esquire Attorney for Defendant t i C 1;1IS: ..._ 7.r l i- ' J- ?I' O U e ? m n °O Q o v Q .d H ? u? + o? Qa a O m .?'e ? ? r n e? ICY ~'N U W CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: EILEEN S. KROH JANICE A. SHETTER -VS- COURT OF COMMON PLEAS TERM, CASE NO: 99-3047 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE 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: 0310812001 MCS on h f of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-242326 2 9 1 5 6- L 3.0 COMMONWEALTH OP P E NN S YLVAN =A COUNTY OP CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM, -VS- CASE NO: 99-3047 JANICE A. SHETTER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PINNACLE HEALTH OF OTHER PHYSICIANS IMAGING CENTRAL OTHER MAGNETIC IMAGING CENTER OTHER TO: W. SCOTT HEMMING, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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: 02/1612001 MCS on behalf of CC: DONALD R. DORER, ESQUIRE JOEL SHUTT - 99HB00094 - 5837CO46568 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE07.-145358 2 9 1 6 6- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL.N-ND EILEEN S. KROH VS JANICE A. SHETTER File No. 99-3047 CIVIL SUBPOENA TO PRODUCE DOCUMEN-TS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.221 TO: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH SYSTE1IS (Name of Penon or Entity) Within tw'en-• (:0) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEP ATTACHED at MCS GROUP _INC. 1601 MARKET ST., 11800, PPHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things rcgaested 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 aoduce the documents or things required by this subpoena, within twenty (20) days after its service, the patty serving this subpoena may seek a court order compelling you to comply with h THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: nnNATn R M)RER ESQ. ADDRESS: 214 SENATE AVE., STE 503 CAM HILL. PA 17011 TELEPHON=• 215-246-0900 SUPREME COURT ID t: ATTORNEY FOR: DEFENDANT BY THE COURT: DATE '20L Prethone /Clerk C' ivt, Deputy Seal of the Court (Eff. 719 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH OF POLYCLINIC 2601 N. 3RD ST. HARRISBURG, PA 17110 RE: 29166 EILEEN S. KROH COPY CERVICAL MRI FILMS OF 08/18/1998 Subject : EILEEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security #: 209-46-1997 Date of Birth: 10-21-1954 SU10-290988 2-9166-L J LO CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM, -VS- CASE NO: 99-3047 JANICE A. SHETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER ESQUIRE 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: 03/08/2001 DONALD R. DORER ESQUIRE Attorney for DEFENDANT DEI1-242327 ?_9166-LIM COMMONWEALTH O V P E NN S YLVAN =A COUNTY OF CTJMSEItLAND IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER TERM, CASE NO: 99-3047 PINNACLE HEALTH OF OTHER PHYSICIANS IMAGING CENTRAL OTHER MAGNETIC IMAGING CENTER OTHER T0: W. SCOTT HENNING, ESQUIRE HCS on behalf of DONALD R. DORER, ESQUIRE 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 HCS or by contacting our local MCS office. DATE: 02/16/2001 MCS on behalf of CC: DONALD R. DORER, ESQUIRE - 99HR00094 JOEL SHUTT - 58370846568 Any questions regarding this matter, contact DONALD R. RORER. ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET Wo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-145358 2 9 1 6 6- C O 2 COMMONWEALTH OF PENhISYLVANIA COUNTY OF CUMBER EILEEN S. KROH VS JANICE A. SHETTER File No. 99-3047 CIVIL SUBPOENA TO PRODUCE DOCUME?\-TS OR THINGS FOR DISCOVERY PURSUA\T TO RULE 4009 22) TO: CUSTODIAN OF RECORDS FOR:PHYSICIANS IMAGING CENTER (Name of Person or °?tite) Within rwen-y 120) days after service of this sub things: are ordered by the court to produce the following documents or CHED at MCS CROUP INC 1601 MARKET ST. 0800, PPHILA,PA 19103 (Addma) 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 parry making this request at the address tilted 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 -oduce the documents or things required by this subpoena, within twenrv (20) days after its service, the parry serving this subpoena may seek a court order compelling you to comply with !-- THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAPoIE _nnmAT.n R_ nnRFR pso ADDRESS: 214 SENATE AVE., STE 503 CAME HTT.T. PA 17011 TELEPHON_ 215-246-0900 SUPRE%fE COURT ID a: ATTORNEY FOR. DEFENDANT BY THE COURT: e DATE _ /S C20--)/ Preeho uuy/Cle 0vil ivision Deputy Seal of the Court (cfL 7/91, EXPLANA'T'ION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PHYSICIANS IMAGING CENTRAL 4349 CARLISLE PIKE CAMP HILL, PA 17011 RE: 29166 EILEEN S. KROH COPY OF CERVICAL MRI FILM OF JULY, 1994 Subject : EILEEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security #: 209-46-1997 Date of Birth: 10-21-1954 SU10-290990 2 9 1 6 6- L 1 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH TERM, -v5- CASE NO: 99-3047 JANICE A. SHETTER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of _ DONALD R. DORER, ESQUIRE 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: 03/08/2001 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-242328 293-66-1,3.2- CObIMONWEALTH OF PENN SY-L.VAIqTa COUNTY' OF cTib4BEpT ANI7 IN THE MATTER OF: COURT OF COMMON PLEAS EILEEN S. KROH -VS- JANICE A. SHETTER PINNACLE HEALTH OF OTHER PHYSICIANS IMAGING CENTRAL OTHER MAGNETIC 31KAGING CENTER OTHER TO: K. SCOTT HE OM. ESQUIRE TERM, CASE NO: 99-3047 M:CS on behalf of DONALD R. DORM. ESQUIRE 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: 02/16/2001 MCS on behalf of CCs DONALD R. DOREH, ESQUIRE - 99HBOO094 JOEL SHUTT - 5837CS46568 Any questions regarding this matter, contact DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MAREET STREET 1800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-145358 2 9 1 6 6- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL.k\'D EILEEN S. KROH VS JANICE A. SHETTER File No. 99-3047 CIVIL SUBPOENA TO PRODUCE DOCUMLN- -rS OR THINGS FOR DISCOVERY PURSUAtiT TO RULE 4009 TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER (Name of Person or Entity) Within twe-n• (:O) days after service of this subpoena, things; CFA at are ordered by the court to produce th CHED e fallowing documents or +ftsu0, PPHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate or compliance, to the patty making this request at the address Hated above. You hate the right to seek in advance, the:easonable cost of preparing the copies or producing the things sought 1f you fail to roduce 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: 214 SENATE AVE. , STE 503 urea x7zt. PA 17011 TELEPHONE- 215-246-0900 SUPREME COURT ID k: ATTORNEY FOR. DEFENDANT BY THE COURT: DATE C;?Op)/ Pmtho or7'/Gtk Citl 1•vuion Deputy Seal of the Court (Eff. 7/97) TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17055 RE: 29166 EILEEN S. KROH COPY OF CERVICAL MRI FILM OF SEPTEMBER, 1996 Subject : EILEEN S. KROH 232 OLD YORK RD., NEW CUMBERLAND, PA 17070 Social Security A4 209.46-1997 Date of Birth: 10-21-1954 SU10-290992 2 9 3 6 6- L 1 2 L CL 7 i ICZ1 i•.+L.' OC - _' Z 4 7 pV _ G ? Z U File No.: 99HB-00094 MAECII!E FOR IS'I'IIo1 CASE Q-R TRIAL (Must be typewritten and spbmittgd in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court. ( ) for trial without a iu_ry. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) Eileen S. Kroh, Plaintiff VS. (Check One) ( ) Assumpsit ( ) Trespass ( x ) Trespass (Motor Vehicle) (Other) Janice A. Shelter, Defendant The trial list will be called on June 12. 2001 Trix''s cocutence on SUN 9. 2001 Pre-trials will be held on June 20, 2001 (Briefs are due 5 days before pro-trials.) (rho party listing this ease for trial shall provide forthwith a copy of the ptaecipe to all counsel, pursuant to local Rule 2141.) _ No. 99-3047 Civil - 19.2L_ Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer. Esquire. Attorney for Defendant: Jacobs & Saba 214 Senate Avenue Suite 503, Camp Hill Pennsylvania 17011: (717) 7 1-0988 Indicate trial counsel for other parties if known: W. Scott Henning. Esquire. Attorney for Plaintiff-, Handier Henning & Rosenberg 1300 Linglectown Rood P.O. Box 1177 Harrisburg. PA 171 717 238-200 This case is ready for trial. Date: April 5. 2001 Signed i,?-- Print Name: Donald R. Dorer. Bcquire Attomey for: Defendant. Janice A. Sheffer 99HB-00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 EILEEN S. KROH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A. SHETTER, DEFENDANT No. 99-3047 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attomey for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe for Listing Case for Trial to be served by regular first class mail upon: W. Scott Henning, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 1 d Date:April 5. 2001 r'._.. Donald R. Dorer, Esquire Attorney for Defendant ?9 (_ L: L N 1 1. 11. 1 1] ?y S w .r a C l n n "?n ?? w Q v C + a tiN ? w 3. Eileen S. Kroh V Janice A. Shetter IN THE COURT OF COMMON PLEAS OF ' CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3047 CIVIL TERM ORDER OF COURT AND NOW, April G, 2001, at the request of the plaintiff, the above-captioned matter is continued from the April 30, 2001 trial term. Counsel is directed to relist the case when ready. By the Court, 1 V4/%\ Georg AHo P. J. W. Scott Henning, Esquire For the Plaintiff Donald R. Dorer, Esquire For the Defendant Court Administrator bb ®;> Ali ?. ?, ., .? ?:. ,_ - ... ,;:_ i 99HB-00094 EILEEN S. KROHO PLAINTIFF VS. JANICE A. SHETTER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTYt PENNSYLVANIA No. 99-3047 CIVIL TERM CIVIL ACTION. LAW JURY TRIAL DEMANDED TO TO THE PROTHONOTARY: Please mark the above-captioned caee settled, discontinued and ended, W. Wott ennin , E quir Handler, e 0 nberg 1300 Linglestown Roa , P.O. Box 1177 Harrisburg, PA 17109 Attorney I.D.# Attorney for Plaintiff Date: : / S?-x) 0 I '?a 99HB-00094 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 EILEEN S. KROH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JANICE A. SHETTER, DEFENDANT No. 99-3047 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe to Settle. Discontinue and End to be served by regular first class mail upon: W. Scott Henning, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Date: August 15, 2001 D nald Dorer, Esquire Attorney for Defendant G 1-5 C) i ' U CC Nr?1uo•l9Sauc•wnuo•ll Mm 'vN rv+nl }II'N'Np1YNM11N4tIgi lM1 IO MOi4M01'1gi11 dIV.^Y