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HomeMy WebLinkAbout99-03255,?? „. -: uy '' era; 1???: ip4i: sv??? ?`: ?, .;,. t`;FI r,.{ ?? ,? ?r ;,?,.; ..L?L??i; S k?' k, ,1r, ;..w I(?$?; p ?, 6? ?V,y i `?? k $. J? ?C r ?. .? P cz aO? °w w aw V NO W LAW OFFICES ,., x• 3-0: CX A?\\V\u, S 3 ?i ... a n m . a U BARBARA E. IRWIN, and TIMOTHY E. IRWIN, her husband, PLAINTIFFS : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v N0.99- -3055 e ? CIVIL ACTION - LAW WILLIAM L. GOSHORN and JURY TRIAL DEMANDED THE PATRIOT NEWS COMPANY, DEFENDANTS PRAECIPE FOR A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please enter my appearance on behalf of the plaintiffs and issue a Writ of Summons against the defendants, William L. Goshorn and The Patriot News Company. Please direct the Sheriff to serve the defendants as follows: Mr. William L. Goshorn 540 North Hanover Street Carlisle, PA 17013 The Patriot News Company 812 Market Street Harrisburg, PA 17101 Respectfully submitted, IRWIN, McK NIGHT & HUGHES By: Marcus A. tgny 60 West -fret Street Carlisl , PA 17013 (717)2 -2353 Supreme Co Attorney for Plaintiffs Date: May 27, 1999 Commonwealth of Pennsylvania County of Cumberland Barbara E. Irwin, and Timothy E. Irwin, her husband Court of Common Pleas to ____99_3255 Civil __-- William L. Goshorn and No. ---------- 19 The Patriot New Company Civil Action Law Mr. William L. Goshorn The Patriot News Company 540 North Hanover. St. 812 Market Street Carlisle, PA 17013 Harrisburg, PA 17101 To _-_ T?be_ William L. Goshorn and The Patri tt New Cmpany You are hereby notified that ---__ Barbara E__Irwin- and Timothy-E-.-Irwin, her husband the Plaintiffs haVecommenced an action in ----- Cji_yil AgioO_. Law__________ - against you which you are required to defend or a default judgment may be entered against you. (SEAL) CUrt s R:_ L903•------_°- Prothonotary May Date -------------- 28 --- ,-----°-'---- i9-9=-- By ----?ix?----?---.?? -??_ r Deputy I Oi i 1 1 ?i 1 1 U1 I Ln C-4 Mi 11 Al i 1 x ?'Aa N ?I 1 mH X 7 W N N N a0 '.ZN cr k C ? .C IQ ? ? N N NN b N +? i ?i N Z•A 0 Np Or?-i i q 1 1 z? C?µNE.?rIM N W HH OxW i 0' Y. JJ44 fpHIWN W ww «ax ? v. a4J 7 tp E Np .i 4 N7 r-I N Q! N E Sln U? H?ct i 1 1 1 1 1 1 1 1 L C SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-03255 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IRWIN BARBARA E ET AL VS GOSHORN WILLIAM L ET AL r' 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: PATRIOT NEWS COMPANY THE but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania. to serve the within WRIT OF SUMMONS On June 21st, 1999 this office was in receipt of the attached return from DAUPHIN County, Pennsylvania. Sheriff's Costs: So answers.. Docketing 18.00 Out of County 9.00 Surcharge 8.00 DEP. DAUPHIN CO. 25.50 ' ma l-? rl x`60 .bU IR[? IN, MCKNIGHT & HUGHES 06/21/1999 Sworn and subscribedo before me this d/nE day of ?.h, 1999 A.D. CLI SHERIFF'S RETURN - REGULAR CASE NO: 1999-03255 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IRWIN BARBARA E ET AL VS. GOSHORN WILLIAM L ET AL TIMOTHY REITZ - , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon GOSHORN WILLIAM L the defendant, at 16:30 HOURS, on the 10th day of June 1999 at 540 NORTH HANOVER STREET CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to WILLIAM L. GOSHORN a true and attested copy of the WRIT OF SUMMONS and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 6.00 .49 Service .00 ? Affidavit .00 Surcharge 6.00 1 ,$T4.00IRWIN, MCKNIGHT & HUGHES 05/21/1999 by Sworn and subscribe to before me this ,)IA* day o: 1f _ 19 A.D. Matt' Jane Snyder Real Estate Depot% William T. Tully Solicitor Dauphin County Harrisburg. Pennsylvania 17101 ph:(717) 255-20,60 fax:(717)255-2889 Jack Lotwick Sheriff Ralph G. McAllister Chief Ixputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania IRWIN BARBARA E Vs County of Dauphin • THE PATRIOT NEWS COMPANY Sheriff's Return No. 1097-T - - -1999 OTHER COUNTY NO. 99-3255-CIVIL AND NOW: June 10, 1999 at 11:50AM served the within SUMMONS upon THE PATRIOT NEWS COMPANY by personally handing to TOM BADEN, MANAGER 1 true attested copy(ies) of the original SUMMONS and making known to him/her the contents thereof at 812 MARKET STREET HARRISBURG, PA 17101-0000 Sworn and subscribed to before me this 14TH day of JUNE, 1999 PROTHONOTARY ? t?ce Of t4g ,?$4pxrff So Answers, ?A?? 1? Sheriifffjof Dauphin` County, Pa. ) By Deputy Sheriff Sheriff's costs: $25.50 PD 06/04/1999 RCPT NO 124631 PB/TH In The Court of Common Pleas of Cumberland Co • unty, Pennsylvania Barbara E. Irwin, et. al. VS. William L. Goshorn, et. al. Serve: The Patriot News Company No. 99-3255 Civil 19 Now, 6/2/99 19_, f SHERIFF OF CUMBERLAND COUNTY, PA do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ?„r?J?,C,.r'..? per. ..ti.T Sheriff of Cumberland County, Pa. Affidavit of Service Now, by handing to attested copy of the original _ the contents thereof. Sworn and subscribed before me this day of 1 g 19 , at o'clock __M, served the a true and and made known to So answers, Sheriff of COSTS SERVICE S MILEAGE AFFIDAVIT County, Pa. S ' Vt L--/ v H aa? N W A w O n ? 6 W F a H w ? a M H ti ? N N CJ m N ti CJ w V M M W l Li •C'i ? EL A Iru u. rn 'j BARBARA E. IRWIN and IN THE COURT OF COMMON PLEAS TIMOTHY E. IRWIN, her husband, CUMBERLAND COUNTY, PA PLAINTIFFS NO. 99-3255 Vs. CIVIL ACTION - LAW WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEFENDANTS JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Defendants William L. Goshom and The Patriot News Company in the above-captioned matter. Respectfully submitted, MARSHALL, SMITH & HADDICK, P.C. l ? 1 Date: September 16, 1999 t;11 I?L Lori Adamcik Kanss, Esquire Attorney I.D. No: 66465 20 South 36th Street Camp Hill, PA 17011 (717) 731-4800 Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this day of September, 1999, I, Lori Adamcik Kariss, hereby certify that I did serve a true and correct copy of the foregoing Entry of Appearance upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: By First-Class Mail: Marcus A. McKnight, III, Esquire IRWIN, MCKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17013 (Counsel for Plaintiffs) 7 Gri Adamcik Kariss, Esqui e IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, PLAINTIFFS VS. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEFENDANTS FILE NO. NO. 99-3255 PRAECIPE AND RULE TO FILE X A COMPLAINT A BILL OF PARTICULARS JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY/CLERK OF SAID COURT: Please issue a rule on the Plaintiffs, Barbara E. Irwin and Timothy E. Irwin, to file a Complaint in the above case within twenty days after service of the rule or suffer a judgment of non pros. DATE: June 14, 2000 Signature: _(Iii ? Print name:- Lori Adamcik Kariss Esquire Attorney for: Defendants Address: 20 South 36"' Street Camp Hill PA 17011 Telephone No.: (717) 731-4800 ID No.: 66465 r IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, PLAINTIFFS Vs. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEFENDANTS FILE NO. NO. 99-3255 PRAECIPE AND RULE TO FILE X A COMPLAINT A BILL OF PARTICULARS JURY TRIAL DEMANDED RULE TO FILE A COMPLAINT NOW, 2000, A RULE IS I-IEREI3Y ISSUED UPON PLAINTIFFS TO FILE A COMPLAINT WITHIN 20 DAYS 01= SERVICE OF THIS RULE OR SUFFER JUDGMENT OF NON PROS. Prot Wiimi yy 13 - Depu -ty (NOTE: File in duplicate) PRO11I0N.-I. C?, I'? 7 " - 3 1 I ? ?rl r i I J1112 J J 1 t' (?` I f ? (I .7 I1 ly 1E ? tr l r 1 _ I 1 J }° F ': ?1 1" 1 1 1 Fh t' r ? C .?? Aly 1} { ` 1 . r F fay: l t V ,r q{'iii r..{+ 'L N t ? I ^ ! . l} d? ft ? 1 !i 1 ? (i zl 4 1 1 . s 11 "rt 'a { d .1 r Ite"l"I}f A/,r YiHr ??4,i ? C ` I } ! +< 3 'r hll °.c,yt rL ?ii?k i?ft}}??.?+ '. 4 k '?* 1'Lo^`uil a N ? 3, ";,. .a ` k r 41. .^5' f `?.CF "?P"?+1v0.A 4 ?' n'?iv ?'? 1?' E '. S , r , 1 1 1 & +5 t«) Y rl ?? U f f?1?$1 ?t? p "t?f{1 ?? r 1 I`i J } S P3A y:?1 gk?va?kl?l?p s Y,. 4?•??,???i?. 'C'wt(?r?+tdeG)r wr 3 ( ti e 1 ?/1 r t i r"\1JXc"?. ?7:1..Vk?d? ni A?,? V ,?y (Vf>}e c }} 3-:. C { r >' } I 2 ;x' h ifi???++ 3Pl?nkyrrgg ?+" n.tl?'°7S24 yn7 f'FxV V.?'j ?Fe S, 1- p ;'t`'?3 tAtf *r Iw a" vt ?"' d, 1 r 1 4? h? ?' b {o ?y y r 'r? , . } v 3 ?c?? ???1 r1'Ss?? 5 t o d b? J+' ? ?F 7Vr'ly{ mc, gg I V r i v ? ,? ? F Itit? ?i6:J gr5 ?•$ t? r t H r L''? 3 d?3 rVrr ?.la.'f??? ?}???i'rl?.' tr t . 1 3? ? } 9 ?l? '}1 vV11? Y r rl t'i ,3 } E ?¢1 i 4??? ? )C ?PSro t } 1 _J C '?? r ,•Y r , r ft}' 1 r ? . z _ LAW OFFICES svzin; e'. /rte BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, PLAINTIFFS V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 99-3255 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 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 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, Pennsylvania 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. BARBARA E. IRWIN and : IN THE COURT OF COMMON PLEAS OF TIMOTHY E. IRWIN, her husband, PLAINTIFFS : CUMBERLAND COUNTY, PENNSYLVANIA V. 99-3255 CIVIL TERM WILLIAM L. GOSHORN and CIVIL ACTION - LAW THE PATRIOT NEWS COMPANY, DEFENDANTS JURY TRIAL DEMANDED COMPLAINT AND NOW, this 30th day of August, 2000 comes the plaintiffs, Barbara E. Irwin and Timothy E. Irwin, her husband, by their attorneys, Irwin, McKnight & Hughes, and makes the following Complaint against the defendants, William L. Goshorn and The Patriot News Company, defendants: 1. The plaintiffs are Barbara E. Irwin and Timothy E. Irwin, her husband, adult individuals residing at 1460 Boiling Springs Road, Boiling Springs, Pennsylvania 17007. 2. The defendant is Mr. William L. Goshom, an adult individual residing at 540 North Hanover Street, Carlisle, Pennsylvania, 17013. 3. The defendant is the Patriot News Company, with an address of 812 Market Street, Harrisburg, Pennsylvania 17101 2 4. On June 3, 1997, the defendant, William L. Goshom, was employed by defendant, The Patriot News Company, and was engaged in the course of his employment on behalf of the defendant, The Patriot News Company, at approximately 9:30 a.m. on said date. 5. At approximately 9:30 a.m. on June 3, 1997, plaintiff, Barbara E. Irwin, was travelling on Pa. Route 74 heading toward Carlisle operating a vehicle owned by her husband, Timothy E. Irwin. As she approached the intersection of Fairview Street in South Middleton Township, Cumberland County, Pennsylvania, a vehicle being a 1987 Plymouth driven by defendant, William L. Goshom, traveled from Fairview Street directly into her lane of travel causing a collision. 6. The defendant, William L. Goshorn, was employed by defendant, The Patriot News Company, and was acting in the course of that employment when he pulled without warning into the lane of travel of the plaintiff, Barbara E. Irwin. 7. The defendant, William L. Goshom, without warning, pulled directly into the lane of travel of the plaintiff, Barbara E. Irwin. The plaintiff, Barbara E. Irwin, had no warning that the defendant would enter the intersection and was unable to avoid the collision which resulted. 8. The proximate cause of the accident was the negligence of the defendant, William L. Goshom, who was acting on behalf of his employee, The Patriot News Company or was acting as the agent of defendant, The Patriot News Company. 3 9. The negligence of the defendant, William L. Goshorn, consisted of the following: a. Failure to properly stop at an intersection controlled by a stop sign; b. Failure to yield the right of way on Pa. Route 74 to the plaintiff, Barbara E. Irwin; C. Failure to warn the plaintiff, d. Failure to keep his vehicle under proper control; e. Failure to travel at a safe speed; and f. Failure to adequately look out for the plaintiffs vehicle as it traveled on Pa. Route 74. 10. At the time of the collision, the road conditions were dry and there was adequate sight distance in the direction of travel of the plaintiff, Barbara E. Irwin, as she approached the intersection where the collision occurred. 11. The defendant, The Patriot News Company, is liable for the negligent actions of its employee and/or agent while he is acting in the course of his employment or as agent for defendant, The Patriot News Company. 12. As a result of the collision, the plaintiff, Barbara E. Irwin, sustained serious inuries to her neck and back. 13. In the collision, the plaintiff sustained damage to the vehicle she was driving which was owned by her husband, Timothy E. Irwin. 4 14. The plaintiff, Timothy E. Irwin, seeks recovery of the damage to his vehicle plus reasonable car rental expenses resulting from the loss of use of said vehicle. 15. The plaintiff, Barbara E. Irwin, has sustained out of pocket medical expenses in excess of Thirty Eight Thousand Seven Hundred Eighty Six and 89/100 ($38,786.89) Dollars. She seeks payment of all medical expenses incurred in excess of her first party medical coverage. 16. The plaintiff, Barbara E. Irwin, will incur future medical expenses which will continue for the rest of her life and seeks payment from the defendants of said expenses. 17. The plaintiff, Barbara E. Irwin, has sustained work loss for which she seeks reimbursement from the defendants. 18. The plaintiff, Barbara E. Irwin, seeks payment of her future work loss. As a result of the injuries she sustained in the accident, plaintiff, Barbara E. Irwin, will not be able to obtain gainful employment for the rest of her life. 19. The plaintiff, Barbara E. Irwin, has sustained serious and permanent injuries to her neck and back for which she seeks damages from the defendants. 5 20. From the date of the accident to the present, Barbara E. Irwin, has sustained severe pain and suffering and has undergone various tests, treatments, and surgeries which have caused her severe pain and suffering. The plaintiff seeks damages from the defendant for said pain and suffering. 21. The permanent nature of the injuries sustained by the plaintiff, Barbara E. Irwin, will cause her to undergo future pain and suffering for which she seeks damages from the defendants. 22. From the date of the accident to the present, the plaintiff, Timothy E. Irwin, has lost the comfort and society of his wife as a direct consequence of the negligent of the defendants. 23. The plaintiff, Timothy E. Irwin, will continue to experience the loss of the comfort and society of his wife, Barbara E. Irwin, due to the nature of her injuries. He seeks damages for the past and future loss of her comfort and society. f.. 6 WHEREFORE, the plaintiffs, Barbara E. Irwin and Timothy E. Irwin, seek damages from the defendants, William L. Goshorn and The Patriot News Company, in the amount in excess of Fifty Thousand and no/100 ($50,000.00) Dollars with interest as permitted by law and the costs of this litigation. Respectfully submitted, IRWIN$ MCKNIGHT & HUGHES By: Marcus . Mc ig squire 60 West Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Attorney for plaintiffs Date: August 30, 2000 7 VERIFICATION The foregoing Complaint is based upon information which has been gathered by counsel and us in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, inforniation and belief. We understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. BARBARA E. IRWIN 0 TIMOT IRWIN Date: AUGUST 30 2000 BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, PLAINTIFFS V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-3255 CIVIL TERM WILLIAM L. GOSHORN and CIVIL ACTION - LAW THE PATRIOT NEWS COMPANY, DEFENDANTS JURY TRIAL DEMANDED 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: Lori Adameik Kariss, Esq. MARSHALL & HADDICK, P.C. 20 South 36th Street Camp Hill, PA 17011 Attorney for Defendants By: IRWIN, McKNIGHT & HUGHES 60 West Pom t Street Carlisle, PA 170 (717) 249-2353 Supreme Court I.D. No. 25476 Date: August 30, 2000 1 _. ?! n `= ? ?? -: ;;` _,' ? ., •r( i "- ,_ J ?? (q ?'? 1: ? .; ti ?'?`?? ?:7 ?_? l) BARBARA E. IRWIN and I TIMOTHY E. IRWIN, her husband, CUMBERLAND IN THE COURT O COMMON PLEAS I COUNTY, PA i PLAINTIFFS • NO. 99-3255 VS. CIVIL ACTION - LAW WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEFENDANTS JURY TRIAL DEMANDED NOTICE TO PLEAD J TO: Barbara E. and Timothy E. Irwin C/o Marcus A. McKnight, 111, Esquire IRWIN, MCKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17013 I i YOU ARE HEREBY NOTIFIED TO PLEAD TO THE WITHIN ANSWER WITH NEW MATTER, OF DEFENDANT/ TO PLAINTIFF'S COMPLAINT WITHIN TWENTY (20) DAYS OF SERVICE OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. i 1 Respectfully submitted, i MARSHALL & HADDICK, P.C. Date: October 25. 2000 Jesar E. Haddick, Jr., Esqu e e Attorney I.D. No: 55666 20 South 361h Street Camp Hill, PA 17011 (717)731-4800 Attorney for Defendants, BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, PLAINTIFFS Vs. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANTS' ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT AND NOW, come Defendants, William L. Goshorn and the Patriot News Company, by and through their counsel, Marshall & Haddick, P.C., and respond to Plaintiffs' Complaint as follows: 1. Denied. After reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained in this paragraph and, therefore, deny same and demand strict proof thereof at time of trial if deemed material. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. The allegations contained in Paragraph 5 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029(e). 6. Denied. The allegations contained in Paragraph 6 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029(e). With regard to the allegations of the employment of William L. Goshorn, it is admitted he was employed by Defendant, the Patriot News Company, and was acting in the course and scope of his employment at the time alleged. 7. Denied. The allegations contained in Paragraph 7 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029(e). 8. Denied. The allegations contained in Paragraph 8 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029(e). It is admitted, however, that at all times relevant hereto, William L. Goshorn was acting in the course and scope of his employment with Defendant, the Patriot News Company. 9. Denied. The allegations contained Paragraph 9 and Subparagraphs 9(a) through (f) of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 10. Denied. The allegations contained Paragraph 10 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 11. Denied. The averments contained in Paragraph 11 of Plaintiffs' Complaint are conclusions of law to which no affirmative response is required. To the extent that a response is required, it is specifically denied that William L. Goshorn, as the employee and/or agent of the Patriot News Company was negligent. On the contrary, Defendant Goshorn acted in a careful, reasonable, proper and prudent manner at all time relevant hereto, 12 The allegations contained in Paragraph 12 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 13. The allegations contained in Paragraph 13 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 14. The allegations contained in Paragraph 14 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 15. The allegations contained in Paragraph 15 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 16. The allegations contained in Paragraph 16 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 17. The allegations contained in Paragraph 17 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 18. The allegations contained in Paragraph 18 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 19. The allegations container' in Paragraph 19 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 20. The allegations contained in Paragraph 20 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 21. The allegations contained in Paragraph 21 of Plaintiffs' Complaint are denied generally in accordance with Pa. R.C.P. 1029 (e). 22. The allegations contained in Paragraph 22 of Plaintiffs' Complaint are denied 1a generally in accordance with Pa. R.C.P. 1029 (e). 23. The allegations contained in Paragraph 23 of Plaintiffs' Complaint are denied generally in accordance with Pa, R.C.P. 1029 (e), WHEREFORE, Defendants, William L. Goshorn and the Patriot News Company, respectfully request that this Honorable court grant judgment in its favor and against Plaintiffs. NEW MATTER 24. Defendants incorporate their responses to Paragraphs 1 through 23 above as if fully set forth herein. 25. Defendants specifically and unequivocally deny any allegation not admitted in Paragraphs 1 through 23 above. 26. Plaintiffs have failed to state a claim upon which relief can be granted. 27. Plaintiffs' claims are barred by the applicable statute of limitations. 28. The claims set forth in Plaintiffs' Complaint are barred, in whole or in part, by the provisions of the Pennsylvania Comparative Negligence Act. 29. The claims set forth in Plaintiffs' Complaint are barred by the Doctrine of Assumption of the Risk. 30. If Plaintiffs did sustain the injuries and damages as alleged in their Complaint, the damages and injuries were caused by individuals or entities over which Answering Defendants would not have the right or ability to control, 31. Any damages allegedly sustained by Plaintiffs were the result of intervening and superceding causes. I. i- r f: i i ?r ?I 'j i ,r 32. At all times relevant hereto, Answering Defendants acted with due care. 33. Some or all of the injuries claimed by the Plaintiffs are the result of pre-existing conditions. 34. Some or all of the damages claimed by the Plaintiffs are not recoverable under Pennsylvania law. 35. Plaintiffs' damages maybe limited by the selection of the limited tort insurance option. 36. Answering Defendants reserve the right to raise all defenses applicable under discovery in this matter progresses. the Pennsylvania Motor Vehicle Code, the Motor Vehicle Financial Responsibility Law and any other statutory or common law defenses that may be determined to be applicable as WHEREFORE, Answering Defendants deny that Plaintiffs are entitled to any relief on their Complaint and demand that judgment be entered in their favor and against the Plaintiffs Respectfully submitted, Date: October 25, 2000 MARSHALL, SMITH & HADDICK, P.C. ????Qjllf7 Lori Adamcik Kanss, Esquire Attorney I.D. No: 66465 20 South 36th Street Camp F{ill, PA 17011 (717)731-4800 Attorney for Defendants CERTIFICATE OF SERVICE 4-- © AND NOW, this hda of C?& Y serq- , 2000, I, Lori Adamcik Kariss, hereby certify that I did serve a true and correct copy of the foregoing document upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: First-Class Mail: Marcus A. McKnight, III, Esquire IRWIN, MCKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17013 (Counsel for Plaintiffs) Lori damci*ariss, Es4uire 1 6" is r VERIFICATION William L.;Gaeban I, hereby verify that the facts set forth in the foregoing Answer to Plaintiffs, Complaint are true and correct to the best of my knowledge, information and belief. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 1'4) 25 / 00 William L. Goshorn 0 VERIFICATION Kurt Hower I, hereby verify that the facts set forth in the foregoing Answer to Plaintiffs' Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 9/8/00 Ku Hower P triot News Comtei r f7'? c.5 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY IRWIN, ET AL Vs. NO. 993255 GOSHOEN, ET AL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 LORI ADAMICK KARISS, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 5/14/01 LORI ADAMICK KARISS, ESQUIRE 20 S 36TH ST CAMP HILL, PA 17011 717-731-4800 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Angelique Cianci File #: M274000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 TO: MARCUS MCKNIGHT NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 4/20/01 LORI ADAMICK KARISS, ESQUIRE 20 S 36TH ST CAMP HILL, PA 17011 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Angelique Cianci Enc(s): Copy of subpoena (s) Counsel return card File #: M274000 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CU?4BFRIAND IRWIN, ET AL Vs. File No. GOSHOEN, ET AL 993255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 YORK NEUROSURGICAL ASSOCS, 2319 S GEORGE ST, YORK PA 17403 TO: _ (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or-thing at -- MEDICAL LEGAL REPRODUCTIONS (,ARFeEds)4940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the docunents or produce things requested h? this subpoena, together with the certificate of ccrtpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde•- c=pelling you to coaply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:LORI ADAMICK KARISS, ESQ ADDRESS: - ? p-S--aETH 0 CAMP-FiY?,t PPr m- 17011 TELEPHONE: SUPREME OOURT ID # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-01 DATE: lo n7? (Eff. 7/97) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: YORK NEUROSURGICAL ASSOCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN ( ) RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ( j NODOCUr4lENTSAVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X•-RAYS ( ) RECORDS / XRAYS have been destroyed ate Aut orize signature or YORK NEUROSURGICAL ASSOCS CUMBERLAND M274000-01 *** SIGN AND RETURN THIS PAGE *** Ca*UNWENLTH OF PENNSYLVANIA ODUNPY OF axemAND IRWIN,.ET AL Vs. GOSHOEN, ET AL File No. 993255 SUBPOENA TO PROOLCE Q22±ENTS QR THIM FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: HUP PENN SPINE CTR, PO BOX 7777 W 8470, PHILA PA 19175-8470 Person or Entity Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doaments or th inRs,: E? ADDENDUM at --- _- MEDICAL LEGAL REPRODUCTIONS A;FAs544 7940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h} this subpoena, together with the certificate of compliance, to the party making thi: request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents w things required by this subpoena within twenty (20) days after its service, the party serving thin .ubpoena may seek a court orde•- (MPa lling you to comply with it. THIS SLEPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: to p :1PTH ST Z'7mP--H=,- PA 17011 TELEPHONE: SUPREPE OOURT ID # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000=02 DATE: I QCLr . Seal of the Wort (Eff. 7/91) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: HUP PENN SPINE CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ) RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced ( ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT'bILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed. Date Authorized signature or HUF PENN SPINE CTR CUMBERLAND M274000-02 * * * SIGN AND RETURN THIS PAGE * * * COMMUNWFALTH OF PENNSYLVANIA, COUM7 OF CUMBF32UM IRWIN, ET AL Vs. File No. 993255 GOSHOEN, ET AL. SUBPOENA TO PRODUCE DOCLRENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009 22 CARLISLE HOSP, 246 PARKER ST, CARLISE PA 17013 TO: ATTN: MEDICAL RECORDS DEPT _ (Name of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunente orsxhingA;HED--ADDL?L at _ - MSDICAL LSOAL RSPRODIICTIONS(A 1®?g&940 DISSTON ST. PHILA., pa? "'-' You maY deliver or mail legible copies of the documents or produce things requested i? this subpoena, together with the certificate of 'corpliance, to the party making th: request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or producing the things sought. If you fail to produce the docrnents or things required by this subpoena within twenty (20) days after its service, the party serving thin s ampelling you to comply with it. Oena may seek a court orde• THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FCLLQe!INO PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS:20 c IgTu 4T TEIF.PHONE:iL-PA- 17011 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-03 GATE: l of of ea l t # - I; (Eff. 7/97) Y ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. No. 993255 GOSHOEN, ET AL CUSTODIAN OF RECORDS FOR: CARLISLE HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ) NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Autfiorize signature or CARLISLE HOSP CUMBERLAND M274000-03 * * * SIGN AND RETURN THIS PAGE * * * IRWIN, ET AL Vs. GOSHOEN, ET AL COM•DNWEALTH OF PENNSYLVANIA COUtM OF C UMBERIAND File No. 993255 SUBPOENA TO PRODUCE DOCI kE< MS OR TH I N3S FOR DISOOVERY PURSUANT TD RULE 4009 22 DR HUGH KNIGHT AND, DR RODNEY HOUSH, PO BOX 100 TO: _ CARLISLE PA 17013 (Name of Person or Ent Within twenty (20) days after service of this subpoenai'you are ordered by the court to produce the following documents orS19$:, __ at MEDICAL LEGAL REPRODUCTIONS C 4940 DISSTON ST., PBILA., PA (ARe.Fds ) You may deliver or mail legible copies of the documents or produce things requested t? this subpoena, together with the certificate of cd*liance, to the party making thi; request at the address listed above. You have the right to seek in advance the rea.onable 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 thin subpoena may seek a court orde•- crnpelling you to omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ AIORESS:---_ 9 .ft- 'ArTR qT TELEPHONE: -L? 17011 SUPRETE COURT ID # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-04 DATE: a 1 a of the Co rt (Eff. 7/97) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: DR HUGH KNIGHT AND ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ( ) NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) X-RAYS Date CUMBERLAND M274000-04 ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Authorized signature or DR HUGH KNIGHT AND * * * SIGN AND RETURN THIS PAGE * * * COMMONWEALTH OF PENNSYLVANIA COUNTY OF CLIMBERLAND IRWIN, ET AL Vs. File No. 993255 GOSHOEN, ET AL SUBPOENA TO PROOtpE DOCLFENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: BELVEDERE MED CTR, 850 WALNUT BOTTOM RD, CARLISLE PA 17013 (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 og-thinas: at _ MEDICAL LEGAL REPR0DUCTI0NS,(AWdss)940 DISSTON ST., PH-ILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of ' carpliance, to the party making this request at the address listed above. You have the right to seek in advance the rea.onable 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 thin, subpoena may seek a court orde•- ompelling you to om ply with it.' THIS SUBPOENA WAS ISSUED'AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: _ c 16TH eT TELEPHONE: --CL; »17011 SUPREME COURT ID #__21 -Y'35-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-05 1 DATE: _QLL 5 l of e BY THE 0Ol1RT: its kputy a. (Eff. 7/97) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. No. 993255 GOSHOEN, ET AL CUSTODIAN OF RECORDS FOR: BELVEDERE MED CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( } PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or BELVEDERE MED CTR CUMBERLAND M274000-05 * * * SIGN AND RETURN THIS PAGE * * * COMMONWEALTH OF PFSII?YLV??` CouNPY OF qP RLAKU IRWIN, ET AL Vs. GOSHOEN, ET AL File No. 993255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR QISODVERY PURSUANT TO RU&E 4009.22 HERSHEY MED CTR, 500 UNIVERSITY DR, HERSHEY PA 17033 TO: ATTN: MEDICAL RECORDS DEPT _ -- (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-tbu:g - ' at MEDICAL LEGAL RSPRO)IICTIONSI,A? , Ku1"..I You may deliver or mail legible copies of the docunents or produce things requested h? this subpoena, together with the certificate of ccmpliance, to the party making thia request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde.- amipelling you to conply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: _ 20 A -ArTH ST -- g-$ -.F* 17 011 TELEPHONE : 215-335-3212 SUPREME COURT ID p - ATTORNEY FOR: 66465 DEFENDANT M274000-06 DATE:- 4,S l l of the Court (Eff. 1/97) Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: HERSHEY MED CTR Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 ALL OUTPATIENT, ORTHOPEDICS DEPARTMENT AND INPATIENT RECORDS. ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ( ) NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( 9 RECORDS / XRAYS have been destroyed at7i- a Authorized signature or HERSHEY MED CTR CUMBERLAND M294000-06 *** SIGN AND RETURN THIS PAGE *** Y , TO: IRWIN, ET AL VS. GOSHOEN, ET AL COMMONWEALTH OF PENNSYLVANIA OOUM OF CUMBERLAND File No. 993255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 40092? ORTHO INST OF PA, 875 POPLAR CHURCH RD, CAMP HILL PA 17011 Name of Person or Entity Within twenty (20) days after service of this subpoena, you are ordered by the court to prostate the following documents orS&ngAsrD7 __ at MEDICAL LEGAL REPRODUCTIONS ,(A;Fdss7940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h? this subpoena, together with the certificate of ccispliance, to the party making thia request at the address listed above. You have the right to seek in advance the rea.onable 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 thin subpoena may seek a co:.irt orde•- srnpelling you to carply with. it., THIS SL6POENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ AMRES.S•_ 2n Z-3zmu em 17011 TELEPHONE: SUPREMc OOl1RT ID # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT BY n M274000-07 DATE: S 'al of the Co rt s (Eff. 7/97) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: ORTHOINST OF PA ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or ORTHO INST OF PA CUMBERLAND M274000-07 *** SIGN AND RETURN THIS PAGE *** . 1 ::1 . ! p IRWIN, ET AL 11 Vs. GOSHOEN, ET AL COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBEERLAM File No. _ 993255 SUBPOENA TO PROOUC£ DOCU!-ENTS OR THINOS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN REHAB ASSOCS, 2601 N 3RD ST, HARRISBURG PA 17110 (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 orSng?S T? at MEDICAL LEGAL (AWtsr940 DISSTON ST. , PHILA„ pA- " ' You may deliver or mail legible copies of the docunents or produce things requested t:. this subpoena, together with the certificate of edrpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.oiable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t-ent% (20) days after its service, the party serving thin subpoena may seek a court or•de• u yelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS' _ Zn a Irmu em 'CAMP H=L,-1A- 17011 TELEPHONE: SUPREME COURT ID p 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-08 BY THE COURT: rothc5F*tary/ark. i i1 D sf rJ DATE: r S 1 of the t ?(,?11?I?'.'I ?? ?.? ?.?,,_ l?J (Eff. 7/47) IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: PENN REHAB ASSOCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ) NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS, ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or PENN REHAB ASSOCS CUMBERLAND M274000-08 * * * SIGN AND RETURN THIS PAGE COM+DNWEALTH OF PENNSYLVANIA COUNPY OF CUMBERfAND IRWIN, ET'AL Vs. GOSHOEN, ET AL File No. 993255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 HEALTHSOUTH REHAB, 175 LANCASTER BLVD, MECHANICSBURG PA 17055 T0: ATTN: MEDICAL RECORDS DEPT (Name of Person or Entitv) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents S-thinATTACAEII-A? WENDU-- at ._-- MEDICAL LEGAL REPRODUCTIONS U sJ940 DISSTON ST., PHILA., PR You may deliver or mail legible copies of the documents or produce things requested h• this subpoena, together with the certificate of carpliance, 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 thin subpoena may seek a court orde• crnpelling you to cm ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: _ n ' T yew TELEPHONE: 17011 SUPREIE COURT ID k__215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-09 DATE. Of the Court (Eff. 7/97) RY 77,F m&T: ADDENDUM TO SUBPOENA I IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB ANY AND ALL RECORDS FROM 9/17/99 TO THE PRESENT. PERTAINING TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ I NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed ate Authorized signature or HEALTHSOUTH REHAB CUMBERLAND M274000-09 *** SIGN AND RETURN THIS PAGE *** i COMP'DNWFALTH OF PENNSYLVANIA COUNTY OF CUM8FRLAtID IRWIN, ET' AL Vs. File No. 993255 GOSHOEN, ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 ORTHO SURG OF CENTRAL PA, 99 NOVEMBER DR, CAMP HILL PA 17011 . TO: (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents ors ngg-_ _ at ii2277 MEDICAL LEGAL REPRODUCTIONS tAgel;sf940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested t•, 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 rea.onable 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 thin subpoena may seek a court orde•- oompelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: - 70 A I F,TH RT -- -££:A?tP--H ALL ; -P? 17 011 TELEPHONE: SUPREME OOURT 10 # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-10 DATE: r r, I S Ockirt „ , it -1 i•. .(Eff. 7/97) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: ORTHO SURG OF CENTRAL PA ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY ELLATING TO REPORTS, ANY HISTORY EXAMINATION OR INDEX TREATMENT RENDERED INFORMATION R TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. made and AVAILABLE. I hereby no record ofrtheyfothat llowinghdocuments search have ( ] has DOCUMENTS been located (CHECK THE APPROPRIATE BOX): ( RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or ORTHO SURG OF CENTRAL PA CUMBERLAND M274000-10% * * * SIGN AND RETURN THIS PAGE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRWIN, ET AL Vs. File No. GOSHOEN, ET AL 993255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS OR DISCOVERY PURSUANT TO RULE 4009,22 KEYSTONE SPINE CTR, 1521 CEDAR CLIFF DR, CAMP HILL PA 17011 T0: (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, U ingX at ??Np NBDICAL LEGAL REPRODUCTIONS(Addrie4s)4940 DISSTON ST., PHIL .,??- You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of ccapliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onable 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 thin subpoena may seek a court orde.- ampelling you to carply with it. THIS SUBPOENA WAS ISSUED AT THE REOUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: _ 20 R l s rm ST NIL-b-,-PA- 17 011 TELEPHONE: SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-11 DATE: S 1 of the tberT (Eff. 7/97) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: KEYSTONE SPINE CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN ( ] 'RECORDS AREATTACHED HERETO., I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or KEYSTONE SPINE CTR CUMBERLAND M274000-11 *** SIGN AND RETURN THIS PAGE *** IRWIN, ET'AL Vs. TO: GOSHOEN, ET AL File No. 993255 SUBPOENA TO PRODUCE DOCLfENTS_NM FOR DISOOVERY PURSUANT TO F-U E gODg p? FRANK DIPRIMA, MS, 920 CENTURY DR, MECHANCISBURG PA 17055 (Name of Person or Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docurents 09 inoru- at NBDICAL LEGAL REPRODUCTIONS, gC g990 DISSTON ST., PHILA., pA (A'Mrdss7 You may deliver or mail legible copies of the domments or produce things requested ty this subpoena, together with the certificate of oaMlianee, to the the party maki reang.onabthli request the address listed above. You have the right to seek in advance copies or producing the things sought. cost of preparing the e: If you fail to produce the documents or thirgs required by this subpoena within twenty (20) days after its service, the party serving thi; =palling you to comply with it. ubPocna may seek a court orde. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF Tof FOLICININO PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: ------_2 0 c I F_ mu T _ TELEPHONE: ?-17011 SUPREPE COURT ID N 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-12 DATE: , r f I S Ca44MEALTH OF PENNMVANIA COUNTY OF CUMBERI.ANr BY Tor -` rr (Eff. 7/97) ADDENDUM TO SUBPOENA ,IRWIN, ET AL Vs. GOSHOEN, ET AL No. 993255 CUSTODIAN OF RECORDS FOR: FRANK DIPRIMA, MS ANY AND ALL MEDICAL/PSYCHIATRIC RECORDS FROM 6/1/99 TO THE PRESENT. PERTAINING TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ J RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. J NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed ate Authorized signature or FRANK DIPRIMA, MS CUMBERLAND M274000-12 * * * SIGN AND RETURN THIS PAGE * * * IRWIN, ET AL Vs. GOSHOEN, ET AL COM MONWE>ALTH OF PENNSYLVANIA C UNIT OF CI24BERIAND File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 3255 CENTRAL. PENN SPINAL ASSOC, 805 SIR THOMAS CT, HARRISBURG PA 17109 TO: (Name of Person or Entity) Within twenty (20) days after service of this 'subpoena, you are ordered by the court to produce the following documents things: SEE ATTACHED Al DENDUM at MEDICAL LEGAL REPRODUCTIONS(AC1*%sst940 DISSTON ST., PHILA., PA You may deliver or msil legible copies of the docunents or produce things requested F:; this subpoena, together with the certificate of compliance, to the party making t.hi; request at the address listed above. You have the right to seek in advance the rea-.able cost of preparing the copies or producing the things sought. If you fail to produce the docurt:ents or things required by this subpoena within t-ent? (20) days after its service, the party serving thin subpoena may seek a court orde• crmpelling you to cmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: 2G S 36T° ST' --CA9F-H1LL, FA' 17011 TELEPHONE: SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M274000-13 DATE: t ?- 1 Seat of the Court 14 . GU (Eff. 7/97) ADDENDUM TO IRWIN, ET AL Vs. GOSHOEN, ET AL SUBPOENA No. 993255 CUSTODIAN OF RECORDS FOR: CENTRAL PENN SPINAL ASSOC ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN ( ) RECORDS ARE ATTACHED IIERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. no record ofrtheyfothat a llowinghdocuments search ( ) has DOCUMENTS been made and AVAILABLE: been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or CENTRAL PENN SPINAL ASSOC CUMBERLAND M274000-13 * * * SIGN AND RETURN THIS PAGE ?r? r ?- ,. '?; __ `? 'i .. , i? ?* IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , IRWIN, ET AL Vs. NO. 993255 GOSHORN, ET AL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena (s) for documents and things pursuant to Rule 4009.22 LORI ADAMICK KARISS, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena (s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: LORI ADAMICK KARISS, ESQUIRE 20 S 36TH ST CAMP HILL, PA 17011 717-731-4800 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD HB ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Angelique cianci File #: M275202 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY IRWIN, ET AL Vs. GOSHORN, ET AL No. 993255 TO: MARCUS MCKNIGHT III NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 5/15/01 Enc(s): Copy of subpoena(s) Counsel return card File #: X275202 LORI ADAMICK KARISS, ESQUIRE 20 S 36TH ST CAMP HILL, PA 17011 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Angeligue Cianci i i, i I- -.may COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IRWIN, ET AL Vs. File No. GOSHORN, ET AL SUBPOENA TO PRODUCE DOCLMNTS OR THINf3S FOR DISCOVERY PURSUANT TO RULE 4029.22 993255 T0: ALEXANDER SPRING REHAB, 27 BROOKWOOD AVE, CARLISLE PA 17013 (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 o VngsL -- at MEDICAL LEGAL REPR0DUCTI0NS,(AWdss5940 DISSTON ST., PHILA., PA - You may deliver or mail legible copies of the documents or produce things requested t• this subpoena, together with the certificate of ca pliance, to the party making thi: request at the address listed above. You have the right to seek in advance the reaaonablE 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 thin subpoena may seek a court orde•- compelling you to cortply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLL0WIN3 PERSON: NAME: LORI ADAMICK KARISS, ESQ pDDRESS----- ?D 36TH ST 17 TELEPHONE; SUPREME OOURT ID R 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M275202-01 DATE: e (bu-t (Eff. 7/91) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHORN, ET AL Docket No. 993255 CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR FERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ) RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ) NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS Z ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or ALEXANDER SPRING REHAB CUMBERLAND M275202-01 * * * SIGN AND RETURN THIS PAGE * * * COFfEtAlFALTH OF PENNSYLVANIA COUNPY OF CUMBERLAND IRWIN, ET AL Vs. GOSHORN, ET AL File No. 993255 SUBPOENA TO PRODUCE DOCIlENTS OR THINGS FOR DISOOV RY PURSUANT TO RULE 4009.22 T0: DR WALTER PEPPELMAN, 805 SIR THOMAS CT, HARRISBURG PA 17109 (Name of Person or ?Entitv) - Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunente or things: SEE A -- at MEDICAL LEGAL REPRODUCTIONS (Acggssf940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested by' this subpoena, together with the certificate of 'earpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onable cost of preoaring the copies or producing the things sought. If You fail to produce the docunents or things required by this subpoena within twenty (201 days after its service, the party serving this subpoena may seek a court orde., (=yelling you to con ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADORESS: TELEPHONE: L,-PA- 17011 SUPREME COURT ID QI 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M275202-02 DATE: Seal a urt i 1 (Eff. 7/97) ADDENDUM IRWIN, ET AL' Vs. GOSHORN, ET AL TO SUBPOENA Docket No. 993255 CUSTODIAN OF RECORDS FOR: DR WALTER PEPPELMAN ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the hest of my knowledge, information and belief all documents or things above mentioned have been produced. [ J NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) X-RAYS gate - CUMBERLAND M275202-02 ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Author!-zed signature or DR WALTER PEPPELMAN * * * SIGN AND RETURN THIS PAGE * * * CDM43NWEALTH OF PENNSYLVANIA OOUNPY OF CU24B RIAND IRWIN, ET AL Vs. File No. 993255 GOSHORN, ET AL SUBPOENA TO PRODUCE . DOCUMENTS OR THINGS FORPISOOVERY PURSUANT TO RULE 4009.22 HARTMAN REHAB ASSOCS, 2645 N 3RD ST STE 490, HARRISBURG PA 17110 T0: _ (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fol lowing documents or -things L- _- at _ MEDICAL LEGAL REPRODUCTIONS1AM(;1ssj940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the docLnmts or produce things requested h? this subpoena, together with the certificate of oaipliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onablE cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twenty (201 days after its service, the party serving this. :subpoena may seek a court orde• anpelling you to comply withAt. THIS SUBPOENA WAS ISSUED AT THE REGUEST OF TIE FOLLO'a I NG PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS: _ "n a zcmH °T TELEPHONE: 17011 SYJPREtE OOURT ID ii 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M275202-03 DATE:- Sea the Court " (Eff. 1/91) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHORN, ET AL Docket No. 993255 CUSTODIAN OF RECORDS FOR: HARTMAN REHAB ASSOCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: BARBARA E IRWIN ADDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ J RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ I NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed ate ut orize signature or HARTMAN REHAB ASSOCS CUMBERLAND M275202-03 *** SIGN AND RETURN THIS PAGE *** . _.__ _.. --- - .a ?_ C) ?. :?" ' C F : 1.}.:. 'i •'? ii???' a.?? ''i ??:J :y t{_ v c? V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY IRWIN, ET AL Vs. NO. 993255 GOSHORN, ET AL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 LORI ADAMICK KARISS, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 06/19/01 File #: M275385 LORI ADAMICK KARISS, ESQUIRE 20 S 36TH ST CAMP HILL, PA 17011 717-731-4800 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD HS ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 Sy: Angelique Cianci IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY IRWIN, ET AL Vs. GOSHORN, ET AL TO: MARCUS MCKNIGHT No. 993255 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUbIENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. !'. Date: 05/21/01 LORI ADAMICK KARISS, ESQUIRE 20 S 36TH ST CAMP HILL, PA 17011 ATTORNEY FOR DEFENDANT ?`. i INQUIRIES SHOULD BE ADDRESSED TO: I MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 j By: Angelique Cianci Enc(s): Copy of subpoena(s) Counsel return card File #: M275385 ?•; rr COn4XMEALTH OF PEt N.SYLVANTA COUNPY OF CUMBERLAND IRWIN, ET AL Vs. GOSHORN, ET AL File No. 993255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 DR ARAN KAPOOR, C/O CARLISLE HOSP PAIN CLINIC, 5 SPRINT DR TO: CARLISLE PA 17013 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following 86ament5 o?-thn _ ng,i 1AeHED ADDENDUM at _ MEDICAL LEGAL REPRODUCTIONS, (AICgr,&A940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b) this subpoena, together with the certificate of compliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rearonable 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 thin subpoena may seek a court orde.- am pelting you to comply with Tit', THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LORI ADAMICK KARISS, ESQ ADDRESS:- 20 g 36TH ST .:r 17011 TELEPHONE: SUPREME COURT ID 215-335-3212 ATTORNEY FOR: 66465 DEFENDANT M275385-01 06/19/01' DATE: Seal th d b( rt (Eff. 1/97) ADDENDUM TO SUBPOENA IRWIN, ET AL Vs. GOSHORN, ET AL Docket No. 993255 CUSTODIAN OF RECORDS FOR: DR ARUN KAPOOR ANY AND ALL PAIN CLINIC RECORDS, CORRESPONDENCE, DOCTOR'S NOTES t; AND ORDERS, CONSULTATOIN AND TEST REPORTS AND ANY AND ALL RECORDS. PERTAINING TO: NAME: BARBARA E IRWIN AbDRESS: 1460 BOILING SPRINGS RD DATE OF BIRTH: 12/16/55 SSAN: 191464092 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN 11 [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed ate Authorized signature or. DR ARUN KAPOOR CUMBERLAND M275385-01 *** SIGN AND RETURN THIS PAGE *** _?•I 111 u BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, PLAINTIFFS Vs. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED WITHDRAWAL / ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Lori Adamcik Kariss, Esquire and enter the appearance of Francis E. Marshall, Jr., Esquire on behalf of Defendants William L. Goshorn and The Patriot News Company in the above-captioned matter. Respectfully submitted, MARSHALL & HADDICK, P.C. Date: June 12, 2003 r->'((r 1?11n r, na M Lori Adamcik Kanss, Esquire Attorney_,D. No: 66465 rya is-t. Marshall, Jr., Esquire rlt rney I.D. No: 27594 South 36th Street amp Hill, PA 17011 (717)731-4800 Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this n day of June, 2003, I, Lori Adamcik Kariss, hereby certify that I did serve a true and correct copy of the foregoing Withdrawal/Entry of Appearance upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: By First-Class Mail: Marcus A. McKnight, III, Esquire IRWIN, MCKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17013 (Counsel for Plaintiffs) G? (??.'l bv?o Lori Adamcik Kariss, Esquire 1. ??• ?)? ' ?. ' / II t. ? • 1 ( !? ?? I I ./ ._. .. il!1 ?. IL- C'I ..) ? ? __) C_l PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( xx ) 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) BARBARA E. IRWIN and TIMOTHY E. IRWIN, PLAINTIFFS V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, DEPENDANTS (check one) ( ) Assumpsit ( ) Trespass (xx) Trespass (Motor Vehicle (other) The trial list will be called on -OCTOBER 7. 2003 and Trials commence on NOVEMBER 3, 2003 Pretrials will be held on OCTTBER 15, 2003 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. _92_-I W_ Civil Term 1g Indicate the attorney who will try case for the party who files this praecipe: _ MARCUS A. Mc IGHT, III ESQ - Indicate trial counsel for other parties if known: FRANCIS E. MARSHALL, JR. This case is ready for trial. Signed: Print Name: MARCUS A HcKNIGHT, All. LSO. Date: _ SEPTEMBER 15, 2003 Attorney for: PLAINTIFFS r ®___ ,.. - ?„ ?? ,_ . - - „ ; _ = ?. ?,: ?:; ? ; ?? ?, i ? : 15. Barbara E. Irwin and Timothy E. Irwin V William L. Goshom and The Patriot News Company IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-3255 CIVIL TERM ORDER OF COURT AND NOW, October 7, 2003, counsel having failed to call the above case for trial, the case is stricken from the November 3, 2003 trial term. Counsel is directed to relist the case when ready. By the Court, Georg .Hoffer, P.J. Alarcus A. McKnight, III, Esquire For the Plaintiff t/Francis E. Marshall, Jr., Esquire For the Defendant Court Administrator ld 10-09-U3 i I PLEO n. 2 James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs COURT OF COMMON PLE) CUMBERLAND COUNTY, PA NO. 99-3255 V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE To the Prothonotary: Please enter the appearance of James K. Thomas, II, Esquire, and Thomas S. Brumbaugh, Esquire and Thomas, Thomas & Hafer, LLP as counsel for Defendant The Patriot News Company in the above matter. Date: October 28, 2003 Respectfully submitted, THOMAS, THOMAS & HAFER, LLP James K. Thoma quire 1. D. No. 1561 Thomas S. Brumbaugh, Esquire I.D. No. 89037 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 441-7060 Attorneys for Defendant, The Patriot News Company CERTIFICATE OF SERVICE AND NOW, this 28th day of October, 2003, I, Michelle E. Wendt, of the la of f the of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 2 for Plaintiffs Attorney Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneys for Defendant, William Goshorn THOMAS, THOMAS & HAFER, LLP Michelle E. Wendt I, , l; is } 1- O Gu N C . fIl(j ? O James K. Thomas, II, Esq., ID #15613 Thomas S. Brumbaugh, Esq., ID #69037 Thomas, Thomas & Hafer, LLP 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17106-0999 (717)237.7100 01"NUARA E. IRWIN an- TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Attorneys for Dolendant, The patio( News Company CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW CERTIF--ATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with a copy of the subpoena attached thereto was mailed or delivered to each party on or about November 7, 2003, to serve subpoenas upon: I • HealthSouth; 2. Frank DiPrima, M.S.; 3. Hospital of University of Pennsylvania; 4. Central Pennsylvania Spinal Associates; 5. Orthopaedic Surgeons; 6• Hartman Rehabilitation Associates; 7. PRISM; 8. Dr. Hugh Knight; 9. Dr. Ralph Lchman/HMC; 10. Christopher Ziegler, Psy.D.; and H. Erie Insurance Company. 2. A copy of the Notice of Intent, including a copy of the proposed subpoenas, is attached to this Certificate. 3. The 20-day period for filing and serving objections to the subpoenas have been waived by all parties as evidenced by the attached correspondence, i 1,. "u 4. The subpoenas which will be served arc identical to the subpoenas attached to the Notice of Intent to Serve Subpoenas. Date: _ f /9 03 Respectfully submitted, THOMAS, THOMAS & HAFER, LLP James K. Thomas, II, quire, I.D No. 15613 Thomas S. Brumbaugh, Esquire, I.D. No. 89037 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 441-7060 Attorneys for Defendant, The Patriot News Company •1. James K. Thomas, II, Esq., ID #15613 Thomas S. Brumbaugh, Esq., ID #69037 Thomas, Thomas & Hater, LLP 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108.0999 bAKBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, , nays for Defendant, The Patriot News j odh E COURT OF COMMON PLEI CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW uetenaant I JURY TRIAL DE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel: Defendant intends to serve subpoenas upon the following providers: I. HealthSouth; 2. Frank DiPrima, M.S.; 3. Hospital of University of Pennsylvania; 4. Central Pennsylvania Spinal Associates; 5. Orthopaedic Surgeons; 6. Hartman Rehabilitation Associates; 7. PRISM; 8. Dr. Hugh Knight; 9. Dr. Ralph Lehman; 10. Christopher Ziegler, Psy.D.; and 11. Erie Insurance Company. The subpoenas to be served are identical to the ones 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 subpoenas. If no objection is made, the subpoenas may be served. Respectfully submitted, & HAFER, James K. Thomas, IL-E I.D. No. 15613 Thomas S. Brumba squire, I.D. No. 89037 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 41-70G0 Date: Afforn _ jJ??W` rlorncys for Defendant, 771e Patriot Ness Company James K. Thomas,'ll, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 tyAhCtdAIXA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HealthSouth, 175 Lancaster Blvd., Mechanicsburg, PA 17055 (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: Any and all medical records regarding Barbara IrMn, DOB: 12116155, SSN: 191-46-4092. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Address) You may datNer or mop legible copies of the documents or produce things requested by this subpoena, together Win the ca ficate of compliance, to the party making this request at the address listed above. You have ft right to seek, In advance, the reasonable cost or preparing the copies or producing the things sought If you fag to produce the documents or things required by this subpoena, wilFJn twenty (20) days after its &w1ce, the party serving thla subpoena may seek a court order compelgng you to conply with IL THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME-. Thomas S. Brumbaugh Esquire ADDRESS 305 N. Front Street POB 999 Hanisburcl PA 17108 TELEPHONE:-(717) 441-7060 SUPREME COURT ID No: 69037 ATTORNEY FOR: Defendant DATE: Prothonotary/Clerk, Civil Division Deputy Seal of the Court James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Attomeys for Defendant. The Pat TIMOTHY E. IRWIN, her husband, Plaintiffs L COURT OF COMMON PLE; CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE W009.22 TO: Frank J. DiPrima, M.S., 920 Century Drive, Mechanicsburg, PA 17055 (Name of Parson or Entity) WBhln twenty (20) days after service of this subpoena, you are ordered by the court to Produce the follovAng documents or things: Any and all medical records regarding Barbara Irwin, DOB: 12/16/55, SSN: 191-46-4092. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Address) . YOU may deliver or man legible copies of the documents or produce things requested by Ile subpoena, upether vAth the certificate of compliance, to the party making this request at the address listed above. You have the right to soak. In advance, the reasonable cost of Preparing the copies or producing the things sought If you fag to produce the documents or things required by this subpoena; within twenty (20) days after Us service may seek a court order compelling you to comply with R , the pally carving this subpoena THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S. Brumbaugh Esquire ADDRESS 305 N. Front Street POB 999 Harrisburg. PA 17108 TELEPHONE: (717)441-7080 SUPREME COURT to NO: 89037 ATTORNEY FOR Defendant DATE: Seat of the Court Prothonotary/Clark, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237.7100 Attorneys for Defendant. The Pat BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs e COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TG RULE 4009.22 TO: Hospital of University of Pennsylvania, 2002 Penn Tower, 399 South 34th St., Philadelphia, PA 19104 (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: Any and all medical records regarding Barbara Irvin, DOB: 12/16155, SSN:191.46-4092. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Address) You may defier Cr man Isp-!a copies of the documents or produce things requested by this subpoena, togother with the certificate of compliance. to the party making d9a, 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 fan to lorv;uce 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 fl. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME Thomas S. Brumbaugh Esquire ADDRESS 305 N. Front Street. POB 999 Harrisburg. PA 17108 TELEPHONE: (717) 441-7060 SUPREME COURT ID No: 69037 ATTORNEY FOR Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, Ii, Esquire Identification Number: 15013 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant TO: Central Pennsylvania Associates, 805 Sir Thomas Court, Harrisburg, PA 17109 ' (Name of person or Entity) WrJtin twenty (20) days after service of this sub Any and all medical records regarding Barbara Irwin bDOB: 92/16/55, SNb191.46-4092or from 4/01 to the present. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street POB 999, Harrisburg, PA 17108 (Address) _ You may deliver or man legible copies of the doatnents w produce things requested by this subpoena, c paring ng th C 'ha party Lady orprodumakiHng ng the this things request sougght the address fisted above. You have the right to seek, In advance, the reasonsble cost p( together xlth the pNfinte of If ypu f1l to produce the documents or tongs may seek a a court onleraornpeiling you fo comreprywqukitedIL hby this subpoena, within tvsnty (2o) days after Its seNke, the party serving this subpoena THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S. Blvmbau h Es uire ADDRESS.305 N. Front Sheet POB 999 karrtsbura, Pq 17108 TELEPHONE:(7171441.7n60 SUPREME COURT ID No: 89037 ATTORNEY FOR- Defendant DATE Seal of the Court Prothonotary/Clerk, Civil Division Deputy l' .i CUMBERLAND COUNTY, pA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Attorneys for Defendant The Patriot BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopaedic Surgeons of Central Pennsylvania, 99 November Drive, Camp Hill, PA 17011 (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 orthings: Any and all medical records regarding Barbara Irwin, DOB: 12/16/55, SSN:191-46-4092, from 4/01 to the present. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Address) You may deliver or ma& legible copies of the documents or produce things requested by this subpoena, together with the certificate d 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 BYou fall to Produce the documents or things required by this subpoena, within twenty (20) days after be service, the party serving this subpoena may seek a court ordercompeaing you to comply with ft. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S. Brumbaugh Esquire ADDRESS 305 N. Front Street. FOB 999 Han-Isbura PA 17108 TELEPHONE: (717)441.7060 SUPREME COURT ID No: 89037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237.7100 BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs t COURT OF COMMON PLEf CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hartman Rehabilitation Associates, 2645 North 3 d Street, Suite 490, Harrisburg, PA 17110 (Name of Person or Entity) Min twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: Any and all medical records regarding Barbara Irwin, DOB: 12/16/55, SSN: 191-46-4092. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Address) You may dolear or marl iogibla copies of the documents or produce things requested by this subpoena, together with the mntitcate or Complier!W, to the party making this request at the address fisted above. You have the right to soak, in advance, the reasonable cost of preparing the Copies or producing the things sought If you tag 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 mum order compelling you to comply with ti, THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME ThomasS Brumbauoh Esattire ADDRESS 305 N. Front Street POB 999 Harrisburn. PA 17106 TELEPHONEs7171441.7060 SUPREME COURT Ia No: 89037 _ ATTORNEY FOR: Defendant _ DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108.0999 (717) 237-7100 Dmmc)/Arw t. IKWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs t cUuRT OF COMMON PL& CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SSUBPOENA TO PRnnt ire nnnLM Nra na rurnrne FOR DISCOVERY at Ioet1ANT TO RULE 4nng 22 TO: PRISM, 175 Lancaster Blvd., PO Box 2028, Mechanicsburg, PA 17055 (Noma of Person or Entity) WDhin twenty (20) days alter SoNks of this subpoena, YOU are obmed by the ooUrt to produce Ulf fotlomng documents or things: Any and all medical racorde regarding Barbara Irwin, DOB: 12/16155, SSN: 191.46.4092, at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Addreu). you may daiver or mail tegbla. copies of the documents or produce things requested by this subpoena, complance, to the party making this request at the address Dated above. You he,@ the right to seek, in adnce, the reasonable cost of ther *" the wcoto of Preparing tlts cooks or producing the things sought. manse fag ka k a court order eomments or things required by this subpoena, vAUdn Menty (20) days after its service, 14 party serving this subpoena peN you thcomplyu K THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME Thomas S Brumbaugh S U re ADDRESs 305 N Front_ cQ".y Harrisburg. PA 17108 TELEPHONE, _f7171441-7Q? SUPREME COURT ID No: 59037 ATTORNEY FOR: Dgf?n_denl DATE: Seal of the Court ProthonotarylClerk, Civil Division Deputy _ James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17106-0999 (717) 237-7100 _Attomeys for Defendant The Patriot BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plainttffs V WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Hugh Knight c/o Dr. Rodney Housh, PO Box 100, Carlisle, PA 17013 (Name of Person or Entfty) Within twsnty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records regarding Barbara Irwin, DOB: 12/16/55, SSN: 191464092. at THOMAS, THOMAS & HAFER. LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 .. (Address) You may deliver or mail legible copies of the documents w produce things requested by this subpoena, together with the certificate of cOmPT rxe, 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 coples or producing the things sought. It You fail to produce the document: or things required by this subpoena, within twenty (20) days after Its service, the party may seek a court order compelling you to compty with R serving this subpoena THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ThO as S. Brumbaugh Esquire ADDRESS 305 N. Front Street PO B 999 Harrisbu 1. PA 17106 TELEPHONE: .(717)441-7060 SUPREME COURT ID No: 89037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Attorneys for Defendant, The Patriot BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODU(' dn?r--NTS OR THINGS EQR DISCOVERY PURSUANT TO RULE 4009 22 TO: Dr. Ralph Lehman, Hershey Medical Conlor, PO Box 860, Hershey, PA 17033 (Name or Person or Entry) Within twenty (20) days after ssrvlcs of this subpoena, you are ordered by the court W produce the following documents or things: Any and all medical records regarding Barbara Irwin, DOB: 12/16/55, SSN: 191-46.4092. at THOMAS, THOMAS & HAFER, LLP, 305 N, Front Slroot, POS 999, Harrisburg, PA 17108 (Addreaa) You may 6e0ver or mail IsplDle copies of Ow doWffwl ts or produce (hinge requested by Oils subpoena, together with the cere0cate of canPOancs, to the party me" this mgwad at OM address ibtsd above. You have the right to seek, in advance, the reasonable cost of preparing that copies or producing the things sought. If you fail to produce the documents or stings Mquked by this subpoena, wtthln Meng (20) days after Its service, the party serving this subpoena may seek a court order competing you b comply hMth O. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S. Brvmbouoh. Esquire ADDRESS 305 N. Front Strout. POD 909 Hansbura. PA 17108 Prothonotary/Clerk, Civil Division TELEPHONE:. (717) 441 -7090 SUPREME COURT ID No: 89037 ATTORNEY FOR: DQlendent DATE: Deputy Seal of the Court James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Attorneys for Defendant, The Patriot News BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 99-3255 V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS. FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Christopher Ziegler, Psy.D., 3544 North Progress Avenue, Suite 110, Harrisburg, PA 17110 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fot rMng documents or things: Any and all medical records regarding Barbara Irwin, DOB: 12116/55, SSN: 191-46-4092. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (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 tre right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought If you fall to produce the documents or things required by this subpoena, Wthin twenty (20) days after is service, the party serving tts subpoena may seek a court order competing you to comply vdth It . THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S. Brumbaugh, Esquire ADDREss 305 N. Front Street. POB 999 Harrisburg, PA 17108 TELEPHONE: (717) 441-7060 SUPREME COURT ID No: 89037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, il, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108.0999 (717) 237-7100 Attorneys for Defendant, The Patriot News Com an BARBARA E. IRWIN and IN THE COURT OF COMMON PLEAS OF TIMOTHY E. IRWIN, her husband, CUMBERLAND COUNTY, PA Plaintiffs NO. 99-3255 V. WILLIAM L. GOSHORN and CIVIL ACTION - LAW THE PATRIOT NEWS COMPANY, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009 22 TO: Erie Insurance Group, 4901 Louise Dr., Rosmoyne Business Center, PO Box 2013, Mechanicsburg, PA 17055-0 (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: Any and all insurance information for claim #010170308850, including application for insurance, the complete policy issued by Erie, the complete claim file and the claim files for any other claims for medical benefits submitted by Barbara Irwin. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (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 fall 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 ft. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S. Brumbaugh. Esquire Seal of the Court ADDRESS 305 N. Front Street. POB 999 Harrisburg, PA 17108 Prothonotary/Clerk, Civil Division TELEPrIONE:f7171441-7060 SUPREME COURT ID No: 89037 ATTORNEY FOR: Defendant Deputy DATE: CERTIFICATE OF SERVICE AND NOW, this day of November, 2003, I, Renee K. Hostetter, Paralegal of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneys fbr Defendant, William Goshorn THOMAS, THOMAS & HAFER, LLP Ell, 'i' 1? epee K. Hostetidr, Paralegal Lehigh Valle), Office: MW Bath Pike, Suite 302, Bethlehem, PA 19017 0 Phone: (610) W-7675 • Fax: (670) 96S-1702 THOMAS, THOMAS & HAFER LLP Ate. ATTORNEYS AT LAW www.tthlaw.com 305 North Front Street, P.O. Box 999, Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 Renee K. Hostetter, Paralegal (717) 441-7063 rostetter@tthlaw.com November 19, 2003 Marcus A. McKnight, III, Esquire IRWIN, MCKNIGHT & HUGHES 6o West Pomfret Street Carlisle, PA 17013 RE: Barbara Irwin v. The Patriot-News Company, et al. Docket No.: 99-3255 (Cumberland County) Our File No.: 220-31292 Dear Attorney McKnight: Thank you for agreeing to waive the 20 day notice requirement to selve subpoenas upon the following: 1. HealthSouth; 2. Frank DiPrima, M.S.; 3. Hospital of University of Pennsylvania; 4. Central Pennsylvania Spinal Associates; 5. Orthopaedic Surgeons; 6. Hartman Rehabilitation Associates; 7. PRISM; 8. Dr. Hugh Knight; 9. Dr. Ralph Lehman/HMC; 1o. Christopher Ziegler, Psy.D.; and 11. Erie Insurance Company. Thank you for your attention to this matter. Very truly yours, Thomas, Thomas & Hafer, LLP Renee K. Hostetter, Paralegal cc: Francis E. Marshall, Jr., Esquire Lehigh Valley Office: 3400 Bath Pike, Suite 302, Bethlehem, PA 18017 • Phone: (610) 868-1675 • Fax: (610) 868-1702 11/1J/fUUJ 1nu LC:DJ PA.1 ULU 400 11U:: 1RUNAD 1I1U01AD RAPER LLr »»» RAXK1JbUKU tPj UU1/UU1 DICKIE MCC.AMEY 8l: CHII,COTE, P.C. n professional corImradon ATTORNM AT LAV 20 SOUTH X"' STREET CAMP HILL, PENNSYLVANIA 17011 TELEPHONE- (717) 7]3-x800 PAX (r17) 7314603 EeMML: mumhaf@dmrtaw,oom i Renee K Hostetter, Paralegal 610.868.1702 1 Marcus A. McKnight, Esq. 249.6354 Frank Mar hell; Esq. n 11-13.03 ? Ham copy to follow XHard copy will -not follow SECRETARY RESPONSIBLE: Barbara-x3001 COMMENTS:' E' 'LIZ4IItl - NO. q0J-3;9-56 AGREE TO WAIVE THE TWENTY DAY NOTICE FOR FILING AND SERVING OBJECTIONS TO THE ELEVEN SUBPOENAS NOTED IN YOUR NOVEMBER 7,203, LETTER. ?CONFIDENTIALITY NOTE''" The documents accompanying this trlecopy transmission contaln information from the law firm of Diekde, M cCamey & Chilcote, P.C. which is confidential and/or legally privileged. The information Is Intended only for the use of the individual or entity named on this transmission sheet. If you are not the Intended recipient, you are hereby noted that any disclosure, copying, dlshibution or the taking of any action in reliance on the contents of this telecopied information is strictly prohibited, and that the documents should be returned to this firm immediately. In this regard, If you have twelved this telecapy in error, please notify us by telephone immediately so that we can arrange for the return of the original documents to us at no cost to you. CERTIFICATE OF SERVICE AND NOW, this ? V\ day of November, 2003, I, Renee K. Hostetter, Paralegal of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneys for Defendant, William Goshorn THOMAS, THOMAS & HAFER, LLP Renee K, Hostetter, Paralegal James K. Thomas, II, Esq., ID #15613 Thomas S. Brumbaugh, Esq., ID #89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108.0999 (717)237.7100 bAKbAKA L. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, NO. 99-3255 CIVIL ACTION - LAW TRIAL As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with a copy of the subpoena attached thereto was mailed or delivered to each party on or about December 4, 2003, to serve subpoenas upon: 1. Pennsylvania State Police, Troop H; and 2. Social Security Administration. 2. A copy of the Notice of Intent, including a copy of the proposed subpoenas, is attached to this Certificate. 3. The 20-day period for filing and serving objections has expired, with no objections being filed to the subpoenas to be served. 4. The subpoenas which will be served are identical to the subpoenas attached to the Notice of Intent to Serve Subpoenas. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP James K. Thomas, II, :s e,1.D. No. 15613 Thomas S. Brumbaug squire, I.D. No. 89037 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 441.7060 Date: 1471'9'f Attorneys for Dtfendarrt, Tire Patriot News Company Attorneys for Defendant, 'rho Patriot News Company IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA James K. Thomas, II, Esq., ID #15613 Thomas s. Brumbaugh, Esq., ID #69037 Thomas, Thomas & Hater, LLP 305 N. Front Street, P.O. Box 999 Hanfsburg, PA 17106.0999 t3AHBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Attorneys /orDSlendant The Patdot News Comoany N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURYTRIAI ni=hAAKtncn NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel: Defendant intends to serve subpoenas upon the following providers: I. Social Security Administration; and 2. Pennsylvania State Police. The subpoenas to be served are identical to the ones 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 subpoenas. If no objection is made, the subpoenas may be served. Respectfully submitted, THOIVIASPM91 IAS & SAFER, LLP •mucs n. i nomas, ll, is e, I.D. No. 15613 Thomas S. Brumba squire, I.D. No. 89037 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 Date: a ?f a? (717) 441-7060 Attorneys for Defendant, The Patriot News Company James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Bdx 999 Harrisburg, PA 17108.0999 (717) 237.7100 6/AKtdARA E. IRWIN an- TIMOTHY E. IRWIN, her husband, Plaintiffs CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Social Security Administration, 533 Walnut Street, Harrisburg, PA 17101 (Name of person or Entity) in twenty (20) days after service of this subpoena, you are ordered by the court to produce the follovAng documents An and all social Securit Administration records for BARBARA IRWIN, DOB: 12/16/5° 2000 to the Present date. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street. FOR ciao PA 17108 (Address) You may deliver or man legible copies of the documents or produce things requested W by wmeparinplianpee,thetoeoptaethe poorny making this request at the address listed above. You have theght to i seek, In subpoena. advance, together the with the cerifticate d able Cost reasonable cost d may seek to You fell produce the documents or things required by this subpoena, within twenty (20) days after Its service, the party s erving court order compelling the o r to comply uvfth ft m this subpoena THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S Bru' b m au h Es cure ADDRESS 305 N. Front Sheet POB 999 Harrisbur PA 17108 TFLEPHONE:(7171441-7060 SUPREME COURT ID No: 69037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108.0999 (717) 237-7100 TIMOTHY E. IRWIN, her husband, Plaintiffs ?wfR r Ur L UIVIMUN PLEAS OF CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: Pennsylvania State Police, Troop H, 1538 Commerce Avenue, Carlisle, PA 17013 (Name of Person or Entity) Within AnYandallydecoor srn udinoltheonlin n you ?w?f dbythecoudroproducethefolloMngdocumentsorthings: Your may deliver or mail legible copies of the documents or produce things requested by this subpoena, together vAth the cortecate of compliance, to the party making this request at the address Rated above. You have the right to seek, In advance, the preparing the copies or producing the things sought reasonable cost of If you fag to produce the documents or things required by this subpoena, xithln Nxanty (20) days agar its service, the party serving this subpoena may seek a court order compelling you to comply Win IL THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME_Momas S. Bnimbauch Esquire Prothonotary/Clerk, Civil Division ADDRESS 3l)5 N. Front Street POB 999 Harrisburc PA 17108 TELEPHONE 1717144 i -7060 Deputy SUPREME COURT ID No: 89037 ATTORNEY FOR: Defendant DATE: _ Seal of the Court CERTIFICATE OF SERVICE AND NOW, this day of December, 2003, I, Renee K. Hostetter, Paralegal of the law finn of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 360' Street Camp Hill, PA 17011 AtloneysforDefendant, William Goshorn THOMAS, THOMAS & HAFER, LLP Renee K. Hostetter, Paralegal Leldgh Valley Office: 3400 Bath Pike, Suite 302, Bethlehem, PA 16017 • Phone: (610) 668-1675 • Fax: (610) 866.1702 CERTIFICATE OF SERVICE AND NOW, this 11 \) day of January, 2004, I, Renee K. Hostetter, Paralegal of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneys for Defendant, William Goshom THOMAS, THOMAS & HAFER, LLP Ranee K. Hostetter, Paralegal ?, ;;: ?., ? '?' ` L?J _, ` ? _ tl' ? _ i_ r>C? c7 ) JIJ_ ' '?I11 LL _ ? 1 ??- iL. ?.? .1'i :1.. Ii_ U r:-? ?:? U C? BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED RUE 40RVE A SUBPOENA CERTIFICATE PURSUANT PREREQUISITE As a Prerequisite to service of a Subpoena for Documents and Things pursuant to Rule 4009.22, Defendants certify that: I 2. A Notice of Intent to Serve the Subpoenas with a copy of the Subpoenas e date attache wluch thereto was mailed to each party at least twenty (20) days prior the Subpoenas are sought to be served. A copy of the Notice of intent including the proposed Subpoenas are attached to this Certificate. 3, No objection to the Subpoenas has been received. 4. The Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent. THOMAS, THOMAS & HAFER, LLP i James K. Thomas, 11, Esquire I.D. Number: 15613 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7617 Date: 277107.1 BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3255 V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant intends to serve subpoenas identical to the ones that are 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 subpoenas. If no objection is made, the subpoenas may be served. THOMAS, THOMAS &_HAF?ER, LLP Date: T qt oY By James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 305 North Front Street P.O. Box 999 Harrisburg, Pa 17108-0999 (717) 237-7100 Attorney for Defendant The Patriot News CompaRl, 27370.1 James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafar, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Attorneys for Defendant, The Patriot h BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant IN THE COURT OF COMMON PLE/ CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DFMANnFn SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: University of Pennsylvania, School of Medicine, 3451 Walnut Street, Philadelphia, PA 19104. (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: Any and all correspondences, hospitalization and medical records regarding treatment rendered on behalf of BARBARA IRWIN. SSN: 191-46-4092, D/O/B: 12/1611955, including, but not limited to patient histories, charts, progress notes, consultation reports, medication charts, statements of injury, diagnosis, prognosis, x-rays or other diagnostics, diagnostic test results and reports without limitation. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (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: Thomas S. Brumbaugh, Esquire ADDRESS 305 N. Front Street POS 999 Harrisburg. PA 17108 TELEPHONE: (717) 441-7060 SUPREME COURT ID No: 69037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108.0999 (717) 237-7100 Attomeys for Defendant The Patriot t BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant CUMBERLAND COUN TY, PA ?v PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: David C. Baker, M.D., 19 Brookwood Avenue, 4104, Carlisle, PA 17013. (Name or Person or Entity) '!thin twenty (20) days after service of this subpoena. the Any and all correspondences, hospitalizyou am ordered by the court to Pmdur ation and medical records regarding n treatment rendered things: on behalf of otesBARBARA IRW, IN. SSN: 191-46-4092, D/O/B: 12/16/1955, includin g , but not limited to patient histories, char progress n consultation reports, medication charts, statements of injury, diagnosis, Prognosis, x-rays diagnostics, diagnostic test results and reports without limitation. or c at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POS 999, Harrisburg, PA 17108 (Address) YOU may stover or mail legible copies this request at the address ss Itstetl aboveor . the documents or You have the rightto produce things 9 advance. the quested by his subpoena, logetherwtth the ceriificale of compliance, to the party making you fall to produce the d reasonable cost of Preparing the copies or Producing compelling you to ramPr?ly with mania it or things required by this subpoena, vProducing the things sought. If tventy (20) days after its service, the Perry THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON; y serving this subpoena may seek a court NAME: Thomas S. Brumbau h Es uire ADDRESS 305 N. Fronl Street POB 999 Harrisbur PA 17108 TELEPHONE* t717)441-7060 SUPREME COURT to No: 89037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy - CERTIFICATE OF SERVICE I, Rick Stains, Jr., Paralegal for the law (inn Thomas, Thomas, Thomas & Hafer, LLP, hereby certify that I have served a true and correct copy of the foregoing document on the following persons by placing a copy of the same in the United States mail, first class mail, directed to their office addresses as follows: Marcus A. McKnight, III, Esq. Irwin McKnight& Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 AtiorneysforDefendant, William Goshon: THOMAS, THOMAS & HAFER, LLP By: Rick Stains, Jr., Paralegal Date: If /Y/U V 273760,1 CERTIFICATE OF SERVICE 1, R ick S twins, Jr., a P aralegal for the I aw finn Thomas, T homas & H afer, LLP, hereby certify that I have served a true and correct copy of the foregoing document on the following person by placing same in the United States mail, postage prepaid, on the date set forth below: Marcus A. McKnight, 111, Esquire IRWIN, MCKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17013 Attorneys for Plaintffs Francis E. Marshall, Jr., Esquire DICKIE, MCCAMEY & CHILCOTE, P.C. 20 S. 36'h Street Camp Hill, PA 17011 Attorneys for Defendant, William Goshorn THOMAS, THOMAS & HAFER, LLP By: Rick Stains, Jr, Paralegal Date: ANN y 27)107.1 C (,? C\j } CA? ( G4_ .T ?4i1ti U t; . d James K. Thomas, II, Esq., ID #15613 Thomas S. Brumbaugh, Esq., ID #89037 Thomas, Thomas & Haler, LLP 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108.0999 (717) 237-7100 BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, NO. 99-3255 CIVIL ACTION - LAW Defendant I JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: I. A Notice of Intent to Serve a Subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party on or about January 27, 2004, to serve a subpoena upon Mutual of Omaha. 2. A copy of the Notice of Intent, including a copy of the proposed subpoena, is attached to this Certificate. 3. The 20-day period for filing and serving objections has expired, with no objections being filed to the subpoena to be served. 4. The subpoena which will be served is identical to the subpoena attached to the Notice of Intent to Serve a Subpoena. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Lea James K. Thomas, 11, V-i No. 15613 Thomas S. Brumb augD. No. 89037 305 Nonh Front StreeP.O. Box 999 Harrisburg, PA 1 7 1 0 8-09 99 (717) 441-7060 Date: 6 < Adore. s•for Dcfendanf, The Patriot News Conipatlp Attorneys for Defendant, The Patriot News Company E COURT OF COMMON PLIzAS UI- CUMBERLAND COUNTY, PA James K. Thomas, II; Esq., ID #15613 Thomas S. Brumbaugh, Esq., ID 989037 Thomas, Thomas & Hafor, UP 305 N. Front Street, P•O. Box 999 Harrisburg, PA 17108.0999 unrtDmmA t. IKVVIN and TIMOTHY E. IRWIN, her husband, Plaintiffs V. CUMBERLAND COUNTY, PA WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, NO. 99-3255 CIVIL ACTION - LAW • ??.? UXI 11Y1'LNT TO SERVE 'A SUBPOENA TO PRODUCE.DOCUMENTS AND TMNGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel: Defendant intends to serve a subpoena upon Mutual of Omaha. The subpoena to be served is identical to the one 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. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP James K. Thomas, II, Esquire, o. 15613 Thomas S. Brumbaugh, E , I.D. No. 89037 305 North Front Street, r Floor P.O. Box 999 Harrisburg, PA 17108-0999 Date: p (717) 441-7060 Attorneys for Defendant, The Patriot News Company James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 BARBARA E. IRWIN and TIMOTHY E, IRWIN, her husband, Plaintiffs CUMBERLAND COUNTY, PA V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant NO. 99-3255 CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mutual of Omaha, Central Pennsylvania Division office, 2405 Park Drive, Suite 206, Harrisburg, PA 17110. - (Name of Parson or Entity) . Within twenty (20) days after service of this subpoena, you am ordered by the mud to produce the following documents or things: inciuamg application for insurance, complete police information, complete claim file and the claim files for any other claims for medical benefits submitted by BARBARA IRWIN. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Address) You may dealer or man legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to to party making this request at the address gated above. You have the dghtto seek In advance, the reasonable cost of preparing the coples orprodudrq the tilngswught If you fall to produce the documents or things required by tils subpoena, wlNth tmnfy (20) days after Its service, the party serving thie subpoena may seek a court order cornpaning you to comply with k THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME Thomas S._Brumbauah. Esquire n)OREss 305 N. Front Street. POB 999 Prothonotary/Clerk, Civil Division Harrisburg. PA 17108 TELEPHONE: (717) 441-7060 Deputy SUPREME COURT to No: 89037 ATTORNEY FOR AOfendant DATE Seal of the Court CERTIFICATE, OF SERVICE AND NOW, this. Mtn -day of January, 2004, I, Renee K. Hostetter, Paralegal of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, 111, Esq. Irvin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickte, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneysfor Defendant, William Goshorn THOMAS, THOMAS & HAFER, LLP JC_Yl'I.LX?C? Renee K. Hostetter, Paralegal Lehigh 1-alky Office: 3400 Bath Pike, Suite 302, Bethlehem. PA 18017 • Phone: (610) 868-1675 • Fax: (610) 868.1702 CERTIFICATE OF SERVICE AND NOW, this ay of February, 2004, I, Renee K. Hostetter, Paralegal of the law fnn of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A, McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneys for Defendant, William Goshora THOMAS, THOMAS & HAFER, LLP C Renee K. I ost tter, Paralegal -- I i CIA : La C i . L. i .v <J James K. Thomas, 11, Esq., ID #15613 Thomas S. Brumbaugh, Esq., ID 989037 Thomas, Thomas 8 Hafer, LLP 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108.0999 (717) 237.7100 Attorneys for Defendant, The Patriot News Company BARBARA E. IRWIN and IN THE COURT OF COMMON PLEAS OF TIMOTHY E. IRWIN, her husband, CUMBERLAND COUNTY, PA Plaintiffs NO. 99-3255 V. CIVIL ACTION - LAW WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant JURY TRIAL DEMANDED As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with a copy of the subpoena attached thereto was mailed or delivered to each party at least 20 days prior to the date on which the subpoenas were served. 2. A copy of the Notice of Intent, including a copy of the proposed subpoenas, are attached to this Certificate. 3. No objection to the subpoenas has been received. 4. The subpoenas which will be served are identical to the subpoenas attached to the Notice of Intent to Serve Subpoenas. Respectfully submitted, THOBiAS, THOhTLAS & HAFER, LLP James K. Thomas, II, Esqu No. 15613 Thomas S. Brumbaugh, quire, I.D. No. 89037 305 North Front Street, 6th Floor P.O. Box 999. Harrisburg, PA 17108-0999 (717) 441-7060 Date: O Attorneltr for Defendant, The Patriot News Company James K. Thomas, II, Esq., ID #15613 Thomas S. Brumbaugh, Esq., ID #89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108.0999 TIMOTHY E. IRWIN, her husband, Plaintiffs COURT OF COMMON PLEI CUMBERLAND COUNTY, PA NO. 99-3255 V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant CIVIL ACTION - LAW NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Marcus McKnight Defendant intends to serve subpoenas upon the following providers: Carlisle Hospital, York Neurosurgical, Frank DiPrima, M.S., Riverside Anesthesia, and Hartman Rehabilitation. The subpoenas to be served are identical to the one 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 subpoenas may be served. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Ja K.\T7iamIais, II, E wire, I.D. No. 15613 Thomas S. Brumbaugh, Esquire, I.D. No. 89037 305 North Front Street, 6111 Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 441-7060 Date: Attorneys for Defendant, The Patriot News Company James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 99-3255 V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Frank J. DIPrima, M.S., 920 Century Drive, Mechanicsburg, PA 17055 (Name of Person or Endo Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the follow,ng documents or things: and all medical records regarding Barbara Irvin, DOB: 12116155, SSN: 191-46-4092, dated November 2003 to the present. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 You may deliver or mail legible copies of the documents or produce wings requested by this subpoena, together with we 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. It you fall to produce the documents or things required by this subpoena, vriwin 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: Thomas S. Brumbaugh Esquire ADDRESS 305 N. Front Street. POB 999 Hanisbum, PA 17108 TELEPHONE: (717)441.7060 SUPREME COURT ID No: 89037 ATTORNEY FOR: Defendant DATE: Prothonotary/Clerk, Civil Division Deputy Seal of the Court James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108.0999 (717) 237-7100 Attorneys for Defendant. The Pat tIAKt$AKA t. IKVVIN and IN THE COURT OF COMMON PLEAS OF TIMOTHY E. IRWIN, her husband, CUMBERLAND COUNTY, PA Plaintiffs NO. 99-3255 V. WILLIAM L. GOSHORN and CIVIL ACTION - LAW THE PATRIOT NEWS COMPANY, -- Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Hospital, 246 Parker Street, Carlisle, PA 17013 (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: Any and all medical records regarding Barbara Irwin, date of birth: 12/16/55, SSN: 191-46.4092 from November 2003 to the present, at THOMAS, THOMAS & HAFER, LLP, 305 N, Front Street, POB 999, Harrisburg, PA 17108 (Address) You may deliver or mail legibie 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 produdng the things sought If you fall 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 oourt order compelling you to comply with It. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S. B umbauah. Esquire ADDRESS_30_5_N, Front Street. POB 999 Harrisburg. PA 17108 _ TELEPHONE: (717) 441-7060 SUPREME COURT ID No: 9037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 TIMOTHY E. IRW IN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant COURT OF COMMON rLtr CUMBERLAND COUNTY, PA NO. 99-3255 CIVIL ACTION - LAW JURY TRIAL DEMANDED ORTHINGS SUFOR DIISCOVERYO PURSUANT TO RULE 009.2 TO: Hartman Rehabilitation Associates, 2645 North 3rd Street, Suite 490, Harrisburg, PA 17110 (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: Any and all medical records regarding Barbara Irwin, DOB: 12116/55, SSN:191-46-4092 from November 2003 to the present. at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 ested by this subpoena, may deliver or mall legible copies of the documents or produce things requtogether with the leic 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: serving this subpoena If you fall to produce the documents or things required by this subpoena, within Monty (20) days after its service, the party may seek a court order compelling you to comply with k. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Thomas S Brumbaugh Esguire ADDRESS 305 N. Front Street POB 999 Hamsbur0 PA 17108 TELEPHONE' (717)441-7060 SUPREME COURT ID No: 89037 ATTORNEY FOR: Defendant DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 BARBARA E. IRWIN and TIMOTHY E. IRWIN, her husband, Plaintiffs IN 1 Ht CUUK I OF COMMON PLEF CUMBERLAND COUNTY, PA NO. 99-3255 V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendant CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: York Neurosurgical, 2319 South George Street, York, PA 17403 (Name of Person or EnOty) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records regarding Barbara Irwin, date of birth: 12/16/55, SSN: 191-46-4092 at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate orcompliance, to the party making this request at the address listed above. You have the right to seek, In advance, rite 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: Thomas S. Brumbauah. Esquire ADDRESS 305 N. Front Street. POB 999 Harisbura. PA 17106 TELEPHONE: (7171441-7060 SUPREME COURT ID No: 89037 Prothonotary/Clerk, Civil Division Deputy ATTORNEY FOR: Defendant DATE: Seal of the Court James K. Thomas, II, Esquire Identification Number: 15613 Thomas S. Brumbaugh, Esquire Identification Number: 89037 Thomas, Thomas & Hafer, LLP 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Attorneys for Defendant, The Patriot News Com an BARBARA E. IRWIN and IN THE COURT OF COMMON PLEAS OF TIMOTHY E. IRWIN, her husband, CUMBERLAND COUNTY, PA Plaintiffs NO. 99-3255 V. WILLIAM L. GOSHORN and CIVIL ACTION - LAW THE PATRIOT NEWS COMPANY, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Riverside Anesthesia Associates, 2025 Technology Parkway, Mechanicsburg, PA 17050 (Name of Person or Entity) Within tmnty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records regarding Barbara Irwin, DOB: 12/16155, SSN: 191-46-4092 at THOMAS, THOMAS & HAFER, LLP, 305 N. Front Street, POB 999, Harrisburg, PA 17108 (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 fall to produce the documents a 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: Thomas S. Brumbaugh Esquire ADDRESS 305 N. Front Street, POB 999 Prothonotary/Clerk, Civil Division Harrisburg. PA 17108 TELEPHONE: (717) 441-7060 SUPREME COURT ID No: 89037 Deputy ATTORNEY FOR: Defendant DATE: Seal of the Court _ CERTIFICATE OF SERVICE AND NOW, this day of January, 2004, I, Renee K. Hostetter, Paralegal of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintffs Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneys for Defendant, William Gosliorn THOMAS, THOMAS & HAFER, LLP ' Renee K. Hostetter, Paralegal Lehigh Valley Office: 34L9 Bath Pike, Suite 302, Bethlehem, PA 18017 • Phone: (610 868.1675 ) i'az: (610) 868•]702 CERTIFICATE OF SERVICE AND NOW, this J day of October, 2004, I, Renee K. Hostetter, Paralegal of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Marcus A. McKnight, III, Esq. Irwin McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 Attorneys for Plaintiffs Francis E. Marshall, Jr., Esq. Dickie, McCarney & Chilcote, P.C. 20 S. 36th Street Camp Hill, PA 17011 Attorneys for Defendant, William Goshorn THOMAS, THOMAS & HAFER, LLP ? Renee K. Hostetter, Paralegal r cQ r.- \u _ L W L_ _ ,_. C D c_? CJ cv BARBARA E. IRWIN and, TIMOTHY E. IRWIN, her husband, Plaintiffs V. WILLIAM L. GOSHORN and THE PATRIOT NEWS COMPANY, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3255 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED 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, III, Esquire, at 60 West Pomfret Street, Carlisle, Pennsylvania 17013. Respectfully submitted, IRWIN & WKNIGH' By: -,' / Marc s A. , c 60 W st Po fn Carlisle, Penns (717) 249-2353 night, , Esquire Street _ani 13 Date: April 25, 2005 BARBARA E. IRWIN and, TIMOTHY E. IRWIN, her husband, Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3255 CIVIL TERM WILLIAM L. GOSHORN and CIVIL ACTION - LAW THE PATRIOT NEWS COMPANY, Defendants JURY TRIAL DEMANDED 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: James K. Thomas, II, Esq. Thomas S. Brumbaugh, Esq. Thomas, Thomas & Hafer P. O. Box 999 Harrisburg, PA 17108 Francis E. Marshall, Jr., Esq. Dickie, McCamey & Chilcote 20 South 36'h Street Camp Hill, PA 17011-4301 IRWIN & 4 By: `Marcus A. McKni t, p11, 'sl 60 West Pomfret S eet Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: April 25, 2005 ,- ?_ cis in ,:_ ?' ??: ,.? ?i.:i :_ ...?:: ?..? r t? i i ? _ r` :n ?j U: ti y .. f `-y - ? iL ?? U Cl L 1