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HomeMy WebLinkAbout99-03625?, :?; ; ,.:- ?' '' ?? ':. . . , ?:: 71099- 3(, 25 CZ: -Q 7,-t, . DSB In The Court of Common Pleas of York County, Pennsylvania 99/06/16 TINA V ROSSON Case Number 97 SU 02267 01 VS Case Type Civil Action HELEN M BUFFINGTON D 001 BUFFINGTON, HELEN M NEALON, JAMES G III 1828 FORSTER STREET HARRISBURG PA 17103 P 001 ROSSON, TINA V MAFFETT, RICHARD F JR 6 RUSSIAN OLIVE DR ETTERS PA 17319 297/05/14 PRAECIPE FOR WRIT OF SUMMONS IN CIVIL ACTION 55.00 0053 0330 97/05/14 WRIT OF SUMMONS ISSUED 0.00 & RETURNED TO ATTORNEY 0053 0330 97/05/14 PROTHY SATISFACTION FEE PAID 5.00 ' 0053 0330 97/06/04 WRIT OF SUMMONS REISSUED 0.00 0062 0096 /.97/06/20 RULE TO FILE A COMPLAINT 0.00 W/CERT SVC 0069 0206 Y97/06/20 ENTRY OF APPEARANCE 0.00 OF JAMES G NEALON III ESQ ON BEHALF OF DEFT 0069 W/CERT OF SVC 0209 i 97/06/27 SHERIFF RETURN OF SERVICE 38.96 DEFT HELEN M BUFFINGTON NOT FOUND IN YORK CO 0072 SHF OF YORK CO 0457 97/06/27 SHERIFF RETURN OF SERVICE 25.50 SVD SUMMONS UPON DEFT HELEN M BUFFINGTON 0072 6/17/97 SHF OF DAUPHIN CO 0457 DSB In The Court of Common Pleas of York County, Pennsylvania 99/06/16 TINA V ROSSON VS HELEN M BUFFINGTON DOCKET ENTRIES 97/07/10 COMPLAINT IN A CIVIL ACTION W/CERT SVC Case Number 97 SU 07267 01 Case Type Civil Action i 97/.07/30 PRELIMINARY OBJECTIONS OF THE DEFENDANT HELEN M BUFFINGTON W/CERT OF SERVICE 99/02/16 STIPULATION TO TRANSFER OF VENUE 99/02/16 ORDER OF COURT MATTER IS TRANSFERRED TO CUMBERLAND COUNTY BY CT JOHN S KENNEDY JUDGE ** E N D O F C A S E P R I N T O U T ** (PROTRIO) 0.00 0077 0084 0.00 0085 0263 0.00 0019 0366 0.00 0019 0366 t.'1iliY1 rflil> from the rec< N.J. of the Court of Coc non Platq of .' rk Cnuttt , Iw V BIN .4 i dub t4Yul 1AU A.D.19= Y1Adr Sweia N. Gates, Prothonotary 4 1. TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT ?? . qq- 3?a5 c : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA NO.97-SU-02267-01 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED AND NOW, this /0 71 day of February, 1999, upon consideration of the Stipulation to Transfer of Venue, it is hereby ordered and decreed that the matter is transferred to Cumberland County. The Prothonotary of York County is directed to effectuate the transfer. to -? W I ' •lii i l0! y ,r. ?" m C! ". ? ??- j = i?ir., O '.?i .. }'--` " ! ?- ?i ? .. ?i?_i 7 C 7 ? - ?% i - ?? - :ilia i- _- 'a u. Cf? ?i r?? J1 f % TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA : NO.97-SU-02267-01 CIVIL ACTION -AT LAW : JURY TRIAL DEMANDED 1. On May 15, 1997, Plaintiff, Tina V. Rosson, commenced this action by filing a Writ of Summons. 2. On July 10, 1995, Rosson filed a Complaint. 3. The Complaint alleges that the action arises out of an automobile accident that occurred on 17'h Street, Camp Hill, Pennsylvania. 4. On July 30, 1997, Defendant, Helen M. Buffington, filed Prellminar > Objections to the Plaintiffs Complaint alleging that venue was not proper. xT o, ?' i 5. The Parties have agreed to have the matter transferred to the Courr6f w L Common Pleas of Cumberland County. f I Therefore, the Parties by and through their respective counsel hereby Stipulate that this Court may transfer the matter to the Court of Common Pleas of Cumberland County. Respectfully submitted, NEALON & GOVEW-? /James G. Nealon, III, Esquire Atty. I.G. #46457 301 Market Street - 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 J, Richard F. Maffett, Jr., Esquire 2201 N. Second Street Harrisburg, PA 17110 4r09011905?? AND NOW, this $4'? day of February, 1999, 1 hereby certify that I have served the foregoing Stipulation to Transfer of Venue on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Richard F. Maffett, Jr., Esquire 2201 N. Second Street Harrisburg, PA 17110 James G. Nealon, III, Esquire Dated: ©,Llo-z I qq v 4 a i a 72 r? ups. a','. 9 0 g 00 A ? RICHARD F. MAFFETT, JR. Attorney at Law 2201 NorttvSecond Street Harrisburg. Pennspanla 17110 (717) 233.4160 o? yy^ r, IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROBSON, Plaintiff 6 Russian Olive Drive Etters, PA 17319 v HELEN M. BUFFINGTON, Defendant 22 South York Street P.O. Box 33 Etters, PA 17319 File No. 7 - D' CIVIL ACTION - LAW PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Summons in the above case. Writ of Summons shall be issued and forwarded to Sheriff. Dated: Richard F. Maffett, Jr , Esq. 2201 North Second Street Harrisburg, PA 17110 (717) 233-4160 Supreme Court ID4 35539 SUMMONS IN CIVIL ACTION TO: Helen M. Buffington YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. n Dated: 5-l/ o Cl.) - u ic) ccj rid Ci e:f _ I?lj O CL ti Cl ] IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROSSON, Plaintiff v HELEN M. BUFFINGTON, Defendant File No. 97-SU-226701 CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY/CLERK OF SAID COURT: Please Re-Issue the Writ of Summons in the above-captioned matter. The Re-Issued Writ of Summons shall be forwarded to Sheriff. Dated: Richard F. Maffett, J ., ES 4, 2201 North Second Street Harrisburg, PA 17110 (717) 233-4160 Supreme Court ID# 35539 Attorney for Plaintiff l0 ° v ? P l? m S _< cn _. n RICHARD F. MAFFETT, JR. Attomey at Law 2201 North Second Straat HarrWwr0, PannayNanla 17110 T"PAan (717) 2334190 June 3, 1997 Fax (717) 233.2342 Office of the Prothonotary York County Court House o 28 East Market Street J York, PA 17401 RE: Tina V. Rosson v Helen M Buffington ?_ r York County No. 97-SU-226701 ?c 0 Dear Sir or Madam: O r'n :7 0 Enclosed please find a Praecipe requesting re-issuanceobf K the Writ of Summons in the above-captioned matter. . The original Writ of Summons, previously issued on May 14, 1997, is being held in the York County Sheriff's Office. Upon reissuance of the Writ of Summons, please leave it with the York County Sheriff for service. Thank you for your attention this matter. Should you have any questions, or require additional information, please contact me. Wit ?Vpest regards, IMA d/, V r Richard F. MafRFM/cs Enclosures r's TINA V. ROSSON : IN THE COURT OF COMMON PLEAS PLAINTIFF : YORK COUNTY, PENNSYLVANIA V. : NO.97SU-02267-01 HELEN M. BUFFINGTON, :CIVIL ACTION - AT LAW DEFENDANT JURY TRIAL DEMANDED tD 0 ? PRAECIPE n TO THE PROTHONOTARY: N n..ti 'm Please issue a Rule upon the Plaintiff to file a Complaint within twenty 120) days or suffer a judgement of non pros. C.4 . A Respectfully submitted, NEALON 8 G By: 9 c y James G. Nealon, III, Esquire Atty. I.D. #46457 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgement of non pros. DATED: ?- IRO h '?7htoiL? . 7 Prothonotary AND NOW, this 18th day of June, 1997, 1 hereby certify that I have served the foregoing Praecipe on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Richard F. Maffett, Jr., Esquire 2201 N. Second Street Harrisburg, PA 17110 James G. Nealon, III, Esquire Dated: 06/18/97 0 0 m 0 0 = n 0 ~ 0 _j (7 0 a m; N i W I¢ 0 N Z o Z N m= Q N ¢ 0 w J W W a a IWQJ 4 F Y Z ` < E m < p N 17 C C I I. :, wn mu•evr?m nomu•n:vm ON MO, axi 1YMO WRMI d Va9'"I a NOISIna r ? 931 U119 lp 97 SU 2267-01 June 26, 1997 In RE: Helen M. Buffington Served by Dauphin County Sheriff as per the attached return. After diligent search and inquiry, this defendant was not found in York County. Out of County Costs Paid by Attorney direct Sheriff's Costs $38.96 Paid So answer 'klliam M. Hose Sheriff LO 7? V -n r? N ,n r ca o a, } Camp of 22Mt Matt of 39mmAuWa Please Serve by 7-3-97 William M. Hose , Sheriff cf Ycrk C--cnty, do hereby depu ze ^' aiZt lerif?f Dauphin Counrv to SerV2 tie w--thin 97-Su-2267-011 Summon ivirt-ACtion ji on irt9toni,1828 Forster Street, haTri*fittrg-€ r--- 4cn Telephone #717-233-5458 C a '7 rr7 Cn v ;n , io Witness my hand t?s_ 10 da_y of June 19 97 - Advance Fee attached Refund monies to atty 00 Richard F. Maffett Jr Sheriff 2201 N. Second St -7 ?---- harrisburg,Pa 17110 RETURN Served the wi upon the within named defendants by handing to and leaving with a true and attested copy of the same at O'clock M, Date: and informed of the contents thereof. Sheriff's Costs S Paid Sworn to this day of So Answers 19 Sheriff 1 Y l Mary Jane Snyder Office of the Sheriff Raal (state Deputy William T. Tully solicitor Dauphin County Harrisburg, Penncylaans 17101 (717) 255.2660 J. R. Lotwick Sheriff COMMONWEALTH OF PENNSYLVANIA 1 COUNTY OF DAUPHIN i SHERIFF'S RETURN No. 1290-T - - -97 OTHER COUNTY NO. 97-SU-2267-01 Flalph G. McAllister Chief Deputy ,- U Mlohae V. Ainegrt Assists let De ty IT R1 _ \ ... rn -OC m 'n 00 s o M L AND NOWs June 17, 1997 at 2157PM served the within SUMMONS IN CIVIL ACTION upon BUFFINGTON HELEN M. by persona=ly handing to BUFFINGTON HELEN M. 1 true attested copy(ies) of the original SUMMONS IN CIVIL ACTION and making known to him/her the contents thereof at 1828 FORSTER ST. Sworn and subscribed to before me this 17TH pa? of JUNE, 1997 PROTHONOTARY HARRISBURG, PA 00000-0000 So Answers, heriff of Dauphin County, Pa. BY _' DEPUTY SHERIFF- _ 5herifPfs,iCdbtsu] $25.50 PD 06/12/97 TS RCPT NO 096191 n IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROSSON, Plaintiff 6 Russian Olive Drive Etters, PA 17319 v HELEN M. BUFFINGTON, Defendant 22 South York Street P.O. Box 33 Etters, PA 17319 File No. g Svc CIVIL ACTION - LAW ?.l PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Summons in the above case. Writ of Summons shall be issued /and forwarded to Sheriff. A LJ ILA J Richard F. Maffett, Jr+,?Esq. 2201 North Second Street w c Harrisburg, PA 17110 ! (717) 233-9160 Supreme Court ID# 35539 W "I ? SUMMONS IN CIVIL ACTION u. a G S TO: Helen M. Buffington YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Dated: ? 7 r`", A4 7'- a? /9-,? ?,2?v L,' ?,? P1 P'1 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROBSON, y Plaintiff File No. 97-SU-2267D1 v J HELEN M. BUFFINGTON, Defendant NOTICE 17 CIVIL ACTION - LAW ' (n YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that, if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff (a). You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DON'T HAVE A LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service of The York County Bar Association The York County Bar Center 137 East Market Street York, Pennsylvania 17401 Telephone: 717-854-8755 NOTICIA LE RAN DENANDADO A LISTED EN LA CORRE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de Is demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demands. Usted puede perder dinero o sue propiedades o otros derechos importantes para usted. n ?; o ??. 9aJ "U'?'?? on's P°1 LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGAGO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION BE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE BE PUEDE CONSEGUIER ASISTENCIA LEGAL. Lawyer Referral Service of The York County Bar Association The York County Bar Center 137 East Market Street York, Pennsylvania 17401 Telephone: 717-854-8755 ??.?`if! j UJfi`! P1 n IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROBSON, Plaintiff File No. 97-SU-226701 v HELEN M. BUFFINGTON, Defendant CIVIL ACTION - LAW COMPLAINT AND NOW, this ,?f? day of July, 1997, comes the Plaintiff, TINA V. ROSSON, by her attorney, Richard F. Maffett, Jr., Esquire, and respectfully represents the following: 1. The Plaintiff, Tina V. Rosson, is an adult individual residing at 6 Russian Olive Drive, Etters, York County, Pennsylvania 17319. 2. Defendant, Helen M. Buffington, is an adult individual residing at 1828 Forster Street, Harrisburg, Pennsylvania 17103. 3. On May 15, 1995, at or about 2:15 p.m., the Plaintiff was operating her vehicle on 17th Street in Camp Hill, Pennsylvania, and had stopped for a red traffic light at the intersection with Hummel Avenue. 4. At that time and place, Defendant was operating her vehicle, headed in the same direction as Plaintiff, on 17th Street, Camp Hill, to the rear of the vehicle of Plaintiff. 5. At the aforesaid time and place, the Defendant failed to stop her vehicle as she approached Plaintiff's vehicle stopped n for the red light, and the front of Defendant's vehicle struck the rear of Plaintiff's vehicle, as a result of which Plaintiff suffered severe physical injury. 6. Said collision resulted from the negligence of Defendant and was due in no manner whatsoever to any act or failure to act on the part of Plaintiff. 7. Defendant owed a duty to other lawful users of the roadways in the Commonwealth of Pennsylvania to operate her vehicle in such a way as not to cause harm or damages to said other persons and to the Plaintiff in particular. 8. The negligence of Defendant consisted of the following: (a) failing to keep her vehicle under proper and adequate control; (b) failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; (c) operating her vehicle in careless disregard for the rights, safety and position of others; (d) traveling too fast for conditions; (e) following too closely; (f) failing to apply her brakes in time to avoid striking Plaintiff's vehicle; (g) failing to operate the vehicle with the skill and care required to safely operate such a vehicle; and, (h) operating her vehicle in violation of the laws of the Commonwealth of Pennsylvania; 2 rft`41 9. As a direct and proximate result of the aforesaid collision, Plaintiff suffered injuries including, but not limited to, the following: (a) cervical, thoracic and lumbar sprain/strain; (b) left shoulder and left arm pain and numbness; and (c) chronic headaches. 10. Plaintiff suffered from pre-existing Temporomandibular Joint disease (TMJ), which was aggravated by the aforesaid collision, and the resulting injuries and treatment therefrom. 11. As a direct and proximate result of the aforesaid collision, Plaintiff suffered aggravation of pre-existing injuries including, but not limited to, the following: (a) cervical, thoracic, and lumbar sprain/strain; (b) sacroiliac strain; (c) traumatic bursitis in her left shoulder; (d) trapezius strain; and, (e) headaches 12. As a result of the injuries she received in this collision, Plaintiff has in the past, and may incur in the future, reasonable and necessary medical and rehabilitative costs and expenses for treatment of her aforesaid injuries. 13. As a further result of this collision, the Plaintiff has suffered a loss of earnings, and impairment of her earning capacity and power, and claim is made therefore. 14. As a further result of this collision, the Plaintiff has 3 ? Irk 'S?"i??}1L? P"'1 r"1 suffered a permanent disability and permanent diminution of her earning power and capacity. 15. As a further result of the aforesaid collision, the Plaintiff has suffered permanent diminution of her ability to enjoy life and life's pleasures. 16. As a result of the injuries she received in this collision, Plaintiff has undergone in the past, is undergoing in the present, and will undergo in the future great pain and suffering. 17. As a direct and proximate result of this collision, the Plaintiff has incurred other financial expenses or losses which exceed the sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Plaintiff demands judgment against Defendant, in an amount in excess of Thirty Thousand ($30,000.00) Dollars, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully submitted, A-4 O'.r rlt Richard F. Maffet Jr., Esquire Attorney I.D. No. 35539 2201 North Second Street Harrisburg, Pennsylvania 17110 (717) 233-4160 4 I, TINA V. ROSSON, have read the foregoing Complaint and hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This verification and statement is made subject to the penalties of 1S Pa. C.S.A. 54904 relating to unsworn falsification to authorities; I verify that all statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C.S.A. 54904. Dated: 7J^ TINA V. ROS W, Plaintiff Ow" ;'"1 ,e?1 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROBSON, Plaintiff File No. 97-SU-226701 v HELEN M. BUFFINGTON, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE The undersigned hereby certifies that he served a true and correct copy of the foregoing Complaint upon counsel of record by depositing same in the United States Mail, postage prepaid, at Harrisburg, PA, addressed as follows: James G. Nealon, III, Esquire Nealon and Gover 301 Market Street, 9th Floor P.O. Box 865 Harrisburg, PA 17108 Dated: kLA j- ? Lo):' - Richard F. Maffett, r., Esq. 2201 North Second Street Harrisburg, PA 17110 (717) 233-4160 Attorney for Plaintiff w W H z > o ? r z z z O z N F ~ u Q zNa a a z ° 5 I Q 2 N O W CcW +J p a>+-r0 En A b u a ut u ? z4 ? W Wuu > a D i a ? Ey > z a H0 kwu E x VRO *! n TINA V. ROSSON PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO THE PROTHONOTARY: n : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA : NO.97-SU-02267-01 : CIVIL ACTION - AT LAW JURY TRIAL DEMANDED Please enter the undersigned's appearance on behalf of the Defendant, Helen Buffington, with regard to the above-captioned matter. 0 T r Respectfully submitted , r> N m -: n NEALON & G 'c 1V o L?( L1 ? 1 By: James G. Nealon, III, Esquire Atty. I.D. #46457 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 n AND NOW, this 18th day of June, 1997, 1 hereby certify that I have served the foregoing Praecipe on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Richard F. Maffett, Jr., Esquire 2201 N. Second Street Harrisburg, PA 17110 _PD?7 James G. Nealon, III, Esquire Dated: 06/18/97 N p 0 m Ir g o 0 W p Q n 0 < 0 m IG J z w I O N o Z i Z w m Q0J " 0 w a a wo <: W Z I E 'm < 0 N Pl C 2 N =" A9591f6•194910•f6' :oN ' 10 Nd61I.q V Y 1YDT U 6{VI JN11YNd1YN.n1Hl .31Y19 T1Y Yl6'TY NEALON & GOVER ' ro? ATTORNEYS AT LAW 301 MARKET STREET • 9' FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 June 18, 1997 Ms. Stacia Gates, York County Prothonotary 28 East Market Street York, PA 17401 RE: Rosson v. Buffington Docket No. 97-SU-02267-01 Dear Ms. Gates: 717-232.9900 717.241.6253 FAX: 717.236-9119 Enclosed herewith, please find an original and one copy of a Praecipe to enter my appearance on behalf of the Defendant in the above-captioned matter. Please file the original and clock-in the copy. Also enclosed, please find an original and two copies of a Praecipe requesting that a Rule be issued upon the Plaintiff to file a Complaint. I would ask that the Praecipe be filed and the Rule issued. Please then conform the extra two copies of the Rule to File a Complaint. I would then ask that you return to me the clocked-in copy of the Praecipe for Entry of Appearance and the two copies of the Rule to File a Complaint. I will then arrange service of the Rule upon the Plaintiffs attorney. Thank you for your cooperation and if you have any questions, please do not hesitate to call. Very tru s `? James G. Nealon, III NEALON & GOVER JGN/slm Enclosure IV W n CD A JAMES G. NEALON III • MATTHEW R. DOVER • BRIAN W. PERRY A PROFMIONAL CORPORAMON N co 0 CD j a ¢ r n 0 J a m LO - 0 t7 m> tz , >. l w x i 0 N Z O Z m 2 0arc NOW J W 0 w a s Z' a m O N m ¢ a a x wwuu•?ovo+u•nai?o •+rm?o :ow wvo+ 'yNl IYHOLLYN11Lw1 ?31v1s lry+n uaswo r T'On Yr19'nY TINA V. ROSSON PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT r` : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA : NO. 97-SU-02267-01 : CIVIL ACTION - AT LAW JURY TRIAL DEMANDED TO: Plaintiff, Tina Rosson and her attorney Richard F. Maffett, Esquire 2201 North Second Street Harrisburg, PA 17110 YOU ARE HEREBY NOTIFIED, that the New Matter set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GPIEI? James G. Nealon, I II, Esquire Atty. I.D. #46457 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 TINA V. ROSSON PLAINTIFF IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA V. : NO.97-SU-02267-01 : CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED PRELIMINARY OBJECTIONS OF TH DEFENDANT. HELEN M. BUFFING10 1. On May 15, 1997, Plaintiff, Tina V. Rosson commenced this action by filing a Writ of Summons. 2. On July 10, 1997, Plaintiff filed a Complaint. 3. This civil action arises out of an automobile accident that occurred on May 15, 1995. The Complaint alleges that the accident occurred at approximately 2:15 p.m. at the intersection of 17th Street and Hummel Avenue, Camp Hill, Pennsylvania. See Complaint at 113. 4. Camp Hill is in Cumberland County. 5. The Complaint alleges that the Defendant, Helen M. Buffington, is an adult individual residing at 1828 Forster Street, Harrisburg, Pennsylvania. See Complaint at 12. 6. Harrisburg is in Dauphin County. 7. Pa.R.C.P. 1006(a) provides as follows: L 1090x? Lb'1 r'1 Except as otherwise provided by subdivisions (b) and (c) of this Rule, an action against an individual may be brought in and only in a County in which he may be served or in which the cause of action arose or where a transaction or occurrence took place out of which the cause of action arose or in any other county authorized by law. In the instant matter, venue is proper only in Dauphin and Cumberland Counties. WHEREFORE, Defendant, Helen M. Buffington urges this Honorable Court to dismiss the Plaintiffs Complaint or alternatively order that the matter be transferred to Dauphin or Cumberland County. Respectfully submitted, NEALON & GPVER By. -1 James G. Nealon, III, Esquire Atty. I.D. #46457 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 'Ll 1090R50263' I1-?) n AND NOW, this 281" day of July, 1997, 1 hereby certify that I have served the foregoing Preliminary Objections on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Richard F. Maffett, Jr., Esquire 2201 N. Second Street Harrisburg, PA 17110 James G. Nealon, III, Esquire 2 f 0908:35CH NEALON & GOvER eoo? ATTORNEYS AT LAW 301 MARKET STREET • 9' FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 July 28, 1997 Ms. Stacia Gates, York County Prothonotary 28 East Market Street York, PA 17401 Dear Ms. Gates: RE: Rosson v. Buffington Docket No. 97-SU-02267-01 717-232-9900 717-241-6253 FAX: 717-236-9119 Enclosed herewith, please find an original and one copy of Defendant's Preliminary Objections with regard to the above-captioned matter. Please file the original and clock-in the copy. Very tr rs ._ James G. Nealon, III NEALON & GOVER JGN/slm Enclosure cc: Richard Maffett, Esquire JAMES G. NEALON III • MATTHEW R. GOVER • BRIAN W. PERRY A PROFMIONAL CORPORAMN ,_?% RICHARD f. MAFFEIT, JR. Attomyr st Law 2201 North Second Street Harrisburg, Pennsylvania 17110 Te"hons (717) 2933-4180 July 9, 1997 Office of the Prothonotary York County Court House 28 East Market Street York, PA 17401 RE: Tina V. Roeson v Helen M. Buff in ton File No. 97-SU-226701 Dear Sir or Madam: fWN Enclosed please find an original and two copies of Plaintiff's Complaint to be filed in your office in the above- captioned matter. Upon filing, kindly return 6wo certified copies to me in the enclosed self-addressed, stamped envelope. Should you have any questions, or require anything additional, please contact me. Wit b es t regards, 1 x0l/ U Richard F. Maffett, Jr. RFM/cs Enclosures Fax (717) 233.2342 cc: James G. Nealon, III, Esquire (w/enc) r°1 r? RICHARD F. MAFFETT, JR. Attomey at Law 2201 North Second Street Harrisburg, Pennsylvania 17110 TiNpbone (717)233.4180 May 13, 1997 Fax (717) 233.2342 7 61/ Office of the Prothonotary York County Court House 28 East Market Street York, PA 17401 77 RE: Tina V. Rosson v Helen M. Buffington Dear Sir or Madam: Enclosed please find the following items in connection with the above-captioned matter: 1. Praecipe for Summons (original and 3 copies); 2. Check made payable to the Prothonotary in the amount of $60.00 for the filing fee; 3. Check made payable to the Sheriff in the amount of $50.00 for service charges; 4. Sheet containing service instructions for the Sheriff; and 5. a self-addressed, stamped envelope. Please file the Praecipe and return a time-stamped copy and receipt to me. I would also appreciate it if you would forward the Writ of Summons, check, and service instruction sheet to the Sheriff for service. Thank you for your assistance in this matter. Should you require anything additional, please contact my office. Wit best regards, ell Richard F. Maffett, Jr. RFM/cs Enclosures TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Defendant, Helen M. Buffington, certifies that: 1. A Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least 20 days prior to the date on which the Subpoena is sought to be served, 2. A copy of the Notice of Intent, including the proposed Subpoena, is attached to this Certificate. 3. No objection to the Subpoena has been received, and 4. The Subpoena, which will be served, is identical to the Subpoena that is attached to the Notice of Intent to Serve the Subpoena. DATE: 7/9/99 cit, JAMES G. NEALON, III, ESQUIRE ATTORNEY FOR DEFENDANT Ion l 301 MARKET STREET. 9": FLOOR P.O. BOX 869 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Computer Aid, Inc. 2245 Kohn Road Harrisburg, PA 17110 In Re: Tina Rosson Social Security* 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal BJB/bjb NEALON & GOVER Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 HELEN M. BUFFINGTON, CIVIL ACTION - AT LAW DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 T0: COMPUTER AID, INC. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, V Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9m Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED :'??? ? •` 77?--? P OTHONOTARY ' * 0 y? Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Computer Aid, Inc. - Personnel Department Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, payroll records or other documents pertaining to: DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Computer Aid, Inc. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 1, Records Custodian for Computer Aid Inc., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Nlealon eAV®N 301 MARKETSTREET• 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17108 17171232.9900 FAX: (717 236-9119 JAMES G. NEALON, IN MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Harrisburg Area Community College 1 HACC Drive Harrisburg, PA 17110 In Re: Tina Rosson Social Security* 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Ix? ( ' (? rJLQA Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HACC - PERSONNEL DEPARTMENT Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9m Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED: 2 /Q?9 jzn ? Seal of the Court PROTHONOTARY EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: HACC - Personnel Department Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, payroll records or other documents pertaining to: DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY M 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Harrisburg Area Community College You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Harrisburg Area Community College, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Nealon 1ATTORNEYS AT LAW July 9, 1999 Erie Insurance Exchange P.O. Box 2013 Mechanicsburg, PA 17055 In Re: Tina Rosson Social Security* 192-42-4663 Dear Records Custodian: 301 MARKET STREET • 9^' FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717)232.9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. COVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400922 TO: ERIE INSURANCE EXCHANGE Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91^ Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED .+. Seal of the Court PROTHONOTAR ' / EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Erie Insurance Exchange ALL DOCUMENTS INCLUDING BUT NOT LIMITED TO. STATEMENTS, PHOTOGRAPHS, MEDICAL RECORDS, MEDICAL BILLS, PEER REVIEW, REPORTS OR OTHER DOCUMENTS PERTAINING TO A CLAIM MADE BY THE SUBJECT LISTED BELOW AS A RESULT OF AN AUTOMOBILE ACCIDENT THAT OCCURRED. IT IS BELIEVED THAT THE CLAIM No. IS 010170176040. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192.42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Erie Insurance Exchange : IN THE COURT OF COMMON PLEAS : YORK COUNTY, PENNSYLVANIA : NO.97-SU-02267.01 : CIVIL ACTION -AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Erie Insurance Exchange, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian 10 I I 301 MARKET STREET • 9^' FLOOR P.O. BOX 063 HARRISBURG, PA 17100 (717) 232.9900 FAX: (717 236-9119 JAMES G. NEALON, III MATTHEW R. COVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Employer's Compensation Services P.O. Box 1478 Lancaster, PA 17608 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: EMPLOYER'S COMPENSATION SERVICE Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9'^ Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:! -2 < 1? 1 % ( "i . n 0; (/C ' PROTHONOT v Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Employer's Compensation Services ALL DOCUMENTS INCLUDING BUT NOT LIMITED TO, STATEMENTS, PHOTOGRAPHS, MEDICAL RECORDS, MEDICAL BILLS, PEER REVIEW, REPORTS OR OTHER DOCUMENTS PERTAINING TO A CLAIM MADE BY THE SUBJECT LISTED BELOW AS A RESULT OF AN AUTOMOBILE ACCIDENT THAT OCCURRED. IT IS BELIEVED THAT THE CLAIM NO. IS N/A. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION -AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Employer's Compensation Services You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Employer's Compensation Services, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Ion 301 MARKET STREET • 9" FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717) 232-9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Leader Insurance/Transport Insurance Co. 1861 Charter Lane, Suite 103 Lancaster, PA 17601 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: LEADER INSURANCE/TRANSPORTINSURANCE Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9' Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9"' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: I? i2 PROTHONOT Y Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Leader Insurance/TransportInsurance ALL DOCUMENTS INCLUDING BUT NOT LIMITED TO, STATEMENTS, PHOTOGRAPHS, MEDICAL RECORDS, MEDICAL BILLS, PEER REVIEW, REPORTS OR OTHER DOCUMENTS PERTAINING TO A CLAIM MADE BY THE SUBJECT LISTED BELOW AS A RESULT OF AN AUTOMOBILE ACCIDENT THAT OCCURRED. IT IS BELIEVED THAT THE CLAIM No. IS 1004720. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 19242-4663 DATE OF BIRTH: 6/2/60 TINA V. ROSSON, PLAINTIFF v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999.03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Leader Insurance/Transport Insurance Co. You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Leader Insurance/Transport Insurance Co., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Ion 301 MARKET STREET • 9" FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717)232.9900 FAX: 1717) 2369119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Prudential Property and N. PA Claims Office Horsham, PA 19044 Casualty Insurance In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please tr iephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEAWN & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PRUDENTIAL PROPERTY AND CASUALTY INSURANCE Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, go Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9o Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: - PROTHONO R Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Prudential Property and Casualty Insurance ALL DOCUMENTS INCLUDING BUT NOT LIMITED TO, STATEMENTS, PHOTOGRAPHS, MEDICAL RECORDS, MEDICAL BILLS, PEER REVIEW, REPORTS OR OTHER DOCUMENTS PERTAINING TO A CLAIM MADE BY THE SUBJECT LISTED BELOW AS A RESULT OF AN AUTOMOBILE ACCIDENT THAT OCCURRED. IT IS BELIEVED THAT THE CLAIM No. IS 46N20143-12095 AND 46P13822-020. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Prudential Property and Casualty Insurance Co. You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Prudential Property and Casualty Insurance Co., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Neil l On 701 MARKET STREET • 9" FLOOR P.O. 80X 865 HARRISBURG, PA 17108 1s 17171272.9900 1 ,- ®ve? FAX: (717 276.9119 ATTORNEYS AT LAW JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KMGHT July 9, 1999 Mutual of Omaha 3316 Farnam Street Omaha, NE 68175 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEAWN & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 HELEN M. BUFFINGTON, ;CIVIL ACTION - AT LAW DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUM'cNTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: MUTUAL OF OMAHA Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 91h Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: 2 y q Seal of the Court PROTHONO R EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Mutual of Omaha ALL DOCUMENTS INCLUDING BUT NOT LIMITED TO, STATEMENTS, PHOTOGRAPHS, MEDICAL RECORDS, MEDICAL BILLS, PEER REVIEW, REPORTS OR OTHER DOCUMENTS PERTAINING TO A CLAIM MADE BY THE SUBJECT LISTED BELOW AS A RESULT OF AN AUTOMOBILE ACCIDENT THAT OCCURRED. IT IS BELIEVED THAT THE CLAIM No. IS N/A. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Mutual of Omaha : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009.23 I, Records Custodian for Mutual of Omaha, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian N 1 801 AfARKET STREET • 9"' FLOOR eq ®M P .O. 18 11 HARRISBURG, PA 171001 17171282.9900 ? 0 ®ve FAX: (717) 236.9119 . ATTORNEYS AT LAW JAMES G. O MATTHEW R. R. GOVER VER BRIAN W. PERRY CHRISTOPHER). KNIGHT July 9, 1999 West Shore EMS 503 N 21" Street Camp Hill, PA 17011 In Re: Tina Rosson Social Security #: 192424663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 HELEN M. BUFFINGTON, :CIVIL ACTION - AT LAW DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WEST SHORE EMS Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9' Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91b Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: S' ^ Seal of the Court PROTHONOTA Y'- EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: West Shore EMS ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612/50 1. TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: West Shore EMS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for West Shore EMS, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on DATE: been produced. Records Custodian ?'.J I I 301 MARKET STREET • 9-' FLOOR P.O. BOX 96S HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236-9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Fairview Township EMS 513 Fishing Creek Road Lewisberry, PA 17339 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT ;JURY TRIAL DEMANDED SUFOR DISC OVERYOPURSUANT TO RULE 4009.22 TO: FAIRVIEW TOWNSHIP EMS Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the _ at the offices of Nealon & Gover, 301 Market Street, 91" Floor, following documents or things: SEE ATTACHED Harrisburg, PA 17101. of the documents or produce things requested by this you may deliver or mail legible copies 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: James G. Nealon, III, Esquire 301 Market Street, 9" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: ?y PROTHON A Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Fairview Township EMS ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Fairview Township EMS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999.03625 : CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Fairview Township EMS, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Ion 301 MARKET STREET • 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (7171232-9900 FAX: (7171236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9. 1999 Sylvan Learning Center 3401 Hartzdale Drive Camp Hill, PA 17011 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: SYLVAN LEARNING CENTER Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, a Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: d Y / 9? , 1.6e:i . b,,, PROTHONOTARV Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Sylvan Learning Center Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, payroll records or other documents pertaining to: DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY M 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Sylvan Learning Center : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 f, Records Custodian for Sylvan Learning Center, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian 301 MARKET STREET-9- FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717) 232.9900 FAX; (717) 236.9119 JAMES G. NEALON, M MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 River Rescue of Harrisburg P.O. Box 2908 Harrisburg, PA 17105 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: RIVER RESCUE OF HARRISBURG Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealont ; ,over, 301 Market Street, 9'" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91" Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED: f`??jq l [ 14116 h: - PROTHONOTARY Seal of the Court 1. EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: River Rescue of Harrisburg ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192.42-4663 DATE OF BIRTH: 612150 TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: River Rescue of Harrisburg You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for River Rescue of Harrisburg, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian L . Ion 701 MARKET STREET • 9- FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717) 212.9900 FAX: (717) 236-9119 JAMES G. NEALON, Ill MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Internal Medicine Associates - 1800 Linglestown Road, Suite 200 Harrisburg, PA 17110 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, 6CUh0"1(;\- Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 HELEN M. BUFFINGTON, ;CIVIL ACTION - AT LAW DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: INTERNAL MEDICINE ASSOCIATE Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon,111, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717.232-9900 Attorney for Defendant BY THE COURT: DATED: 6uw X25'/ 9? Or Z PROTHONOTARY/ Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Internal Medicine Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2160 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 HELEN M. BUFFINGTON, :CIVIL ACTION - AT LAW DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Internal Medicine Associates You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Internal Medicine Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian salon 301 MARKET STREET • 9TM FLOOR P.O. BOX 665 HARRISBURG, PA 17106 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, M MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT A. Z. Ritzman Associates 3508 Trindle Road Camp Hill, PA 17011 July 9, 1999 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, I- I/n ^ Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999.03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2 2 TO: A.Z. RITZMAN ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9'" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91^ Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: ,.y /995 Ll, , Pc It c( PROTHONOT"Y' Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: A.Z. Ritzman, Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: A.Z. Ritzman Associates : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999.03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for A.Z. Ritzman Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian L . Ion 301 MARKET STREET - 9- FLOOR P.O. BOX 863 HARRISBURG, PA 17108 1717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, IB MATTHEW R. COVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT Robert C. Zabinski, D.C. 3028 Market Street Camp Hill, PA 1701-i July 9, 1999 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, LUD BJB/bjb Enclosures Barbara Baker, Paralegal NEALON & GOVER TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ROBERT C. ZABINSKI, D.C. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9m Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: 2 5" 17 e,.'., P oP _ ,m. PROTHONOTARR Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For Robert C. Zabinski, D.C. ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2150 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Robert C. Zabinski, D.C. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009 23 I, Records Custodian for Robert C. Zabinski, D.C., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian OX 86S me on 301 MARKET STREET • 9- P.O. BOFLOOR X 863 HARRISBURG, PA 17108 • (717) 232-9900 FAX: (717) 236-9119 ATTORNEYS AT LAW JAMES O H FR R. G O V BRIAN W. PERRY CHRISTOPHER). KNIGHT July 9, 1999 Valley Green Family Practice 1790 Old Trail Road, Suite A Etters, PA 17319 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, 1?6?bccAa-- barba)a Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2 2 TO: VALLEY GREEN FAMILY PRACTICE Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, gm Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED: / ??5 1999 /C PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For Valley Green Family Practice ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2150 TINA V. ROSSON, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Valley Green Family Practice You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009.23 I, Records Custodian for Valley Green Family Practice, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DA Records Custodian 301 MARKET STREET • 9- FLOOR P.O. BOX 86S HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER]. KNIGHT July 9, 1999 Central PA Oral and Maxillofacial Surgeons 4700 Union Deposit Road, Suite 260 Harrisburg, PA 17111 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ?va)Ao?- ?G?rV Q1U BJB/bjb Enclosures Barbara Baker, Paralegal NEALON & GOVER TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CENTRAL PA ORAL AND MAXILLOFACIAL SURGEONS Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: cy P _?,-L, PROTHONO'FAW( Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Central PA Oral and Maxillofacial Surgeons ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Central PA Oral and Maxillofacial Surgeons You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Central PA Oral and Maxillofacial Surgeons, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian nealo11 `'1ftwv®r 301 MARKET STREET • 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN w.. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Polyclinic Medical Center 2601 N 3ftl Street Harrisburg, PA 17110 In Re: Tina Rosson Social Security #: 192424663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal BJB/bjb NEALON & GOVER Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: POLYCLINIC HOSPITAL Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 91 Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED - PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Polyclinic Medical Center ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Polyclinic Medical Center : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999.03625 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. I, Records Custodian for Polyclinic Medical Center, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Neelon '@Vover RWNM%MM July 9, 1999 South Central Neurologic Associates 805 Sir Thomas Court Harrisburg, PA 17109 In Re: Tina Rosson Social Security #: 192424663 Dear Records Custodian: 301 MARKET STREET • 9- FLOOR P.O. BOX 86S HARRISBURG, PA 17108 (717) 2329900 FAX: (717) 2369119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999413625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: SOUTH CENTRAL NEUROLOGIC ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. You may deliver or mall 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 fell 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: James G. Nealon, III, Esquire 301 Market Street, 91' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: South Central Neurologic Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192424663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: South Central Neurologic Associates You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for South Central Neurologic Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Ion 301 MARKET STREET • 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717)232.9900 FAX; )717) 236.9119 JAMES G. NEALON, M MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER]. KNIGHT July 9, 1999 Retina and Oculoplastic Consultants, P.C. Pennview Place 220 Grandview Road Camp Hill, PA 17011 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, P-)Cwbct--?- C?'- (?CA Rte. Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: RETINA AND OCULOPLASTIC CONSULTANTS, P.C. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9' Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91° Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATEDy` ii,,, 1 s" Seal of the Court PROTHONOTAR1741- EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Retina and Oculoplastic Consultants, P.C. ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2150 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT : JURY TRIAL DEMANDED NOTICE TO: Retina and Oculoplastic Consultants, P.C. You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Retina and Oculoplastic Consultants, P.C., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Neal®n ?-IAMWBN 301 MARKET STREET • 9- FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717)232.9900 FAX: (717) 236.9119 JAMES G. NEALON, M MATTHEW R. GOVER, BRIAN W. PERRY CHRISTOPHER]. KNIGHT July 9, 1999 Arlington Orthopedics 805 Sir Thomas Court Harrisburg, PA 17109 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ARLINGTON ORTHOPEDICS Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9' Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91° Floor Harrisburg, PA 17101 717.232-9900 Attorney for Defendant BY THE COURT: DATED: yP ,PROTHONO ARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Arlington Orthopedics ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Arlington Orthopedics : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Arlington Orthpedics, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian 301 MARKET STREET • 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717( 236.9119 JAMES G. NEALON, Ill MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Capitol Area Pain Management Associates 2447 N. 3" Street Harrisburg, PA 17110 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, P-) CS cam- c--- ' -X-P-? Barbara Baker, Paralegal BJB/bjb NEALON & GOVER Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CAPITOL AREA PAIN MANAGEMENT ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9' Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9t° Floor Harrisburg, PA 17101 717.232-9900 Attorney for Defendant BY THE COURT: DATED: /9 99 tom.,, r=te af. n-', I,,J PROTHONOTARY/ Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Capitol Area Pain Assoc. ANY AND ALL MEDICAL RECORDS,. OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2150 TINA V. ROBSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Capital Area Pain Management Associates You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE I, Records Custodian for Capital Area Pain Management Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Ion 301 MARKET STREET • 9- FLOOR P.O. BOX OX 96S HARRISBURG, PA 17109 108 swim (717) 232.99110 FAX: (717( 2169119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July g, 1999 Karkuff, Lennington and Hilbolt Physical Therapy 899 S Arlington Avenue Harrisburg, PA 17109 In Re: Tina Rosson Social Security #: 19242-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: KARDUFL LENNINGTON AND HILBOLT PHYSICAL THERAPY Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 91" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:.,, X75; /yi`I et, r" /1? '6L' h_' TT PROTHONO AR'f Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Karkuff, Lennington and Hilbolt Physical Therapy ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-0663 DATE OF BIRTH: 612150 salon 301 MARKET STREET • 9' FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 132.9900 FAX: (717) 136-9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Community General Osteopathic Hospital 4300 Londonderry Road Harrisburg, Pa 17105 In Re: Tina Rosson Social Security* 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ? Barbara Baker, Paralegal NEALON & GOVER BJBrojb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-03626 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE= DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon 6 Gover, 301 Market Street, go Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9o Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: ?( 19 C)9 Seal of the Court PROTHONOTARY EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Community General Osteopathic Hospital ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION -AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Community General Osteopathic Hospital You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Community General Osteopathic Hospital, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Nealon ? _ Dover A ORNEYS AT LAW 301 MARKET STREET • 9^ FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, W MATTHEW R. COVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Occupational Rehab and Research Associates 805 South Arlington Avenue Harrisburg, PA 17109 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: OCCUPATIONAL REHAB AND RESEARCH ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, ill, Esquire 301 Market Street, 9" Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED. u7 S' /99 5, PROTHON 6AR Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Occupational Rehab and Research Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612150 TINA V. ROSSON, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Occupational Rehab and Research Associates You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009.23 I, Records Custodian for Occupational Rehab and Research Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian eaten 301 MARKET STREET • 9- FLOOR P.O. BOX 965 HARRISBURG, PA 17109 17171232.9900 FAX: (717) 236-9119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT Community Imaging Associates 805 South Arlington Avenue Harrisburg, PA 17109 July 9, 1999 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the -ubpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 HELEN M. BUFFINGTON, :CIVIL ACTION - AT LAW DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: COMMUNITY IMAGING ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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 tail 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: S 9 49 G t x 1' Seal of the Court PROTHONOTA Y?- EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Community Imaging Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612150 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Community Imaging Associates You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009.23 I, Records Custodian for Community Imaging Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian m 301 MARKET STREET • 9" FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236-9119 JAMES G. NEALON, III MATTHEW R. COVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 David W. Gerhart, D.C. 303 South 32nd Street Camp Hill, PA 17011 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ?C?`- ?) `A-? Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 HELEN M. BUFFINGTON, CIVIL ACTION - AT LAW DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DAVID W. GERHART, D.C. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, go Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, go Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:. V..../9 C/ % 6" t 2- /A , Seal of the /Court PROTHONOTbF EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: David W. Gerhart, D.C. ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-03625 HELEN M. BUFFINGTON, DEFENDANT TO: David W. Gerhart, D.C. CIVIL ACTION -AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009.23 I, Records Custodian for David W. Gerhart, D.C., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on DA been produced. Records Custodian N ' 301 MARKET STREET • 9^' FLOOR ®M a P.O. BOX 868 HARRISBURG, PA 17108 9 1 0 ovo r FAX: 17171 236.911 JAMES G. NEALON, RI MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Jeffrey A. Marks, D. P.M. 940 Century Drive Mechanicsburg, PA 17055 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEAEON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: JEFFREY A. MARKS, DPM Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SF.E ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9' Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, P Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: ?s /x}99 PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Jeffrey A. Marks, DPM ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: UP to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Jeffrey A. Marks, D.P.M : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999.03626 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE I, Records Custodian for Jeffrey A. Marks, D.P.M., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on DATE: been produced. Records Custodian N T-1 Ion 301 MARKET STREET - V'FLOOR P.O. BOX 965 HARRISBURG. PA 17109 (717)232.9900 FAX: (717) 236.9119 JAMES G. NEALON, RI MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT Lebanon Magnetic Imaging 855 Tuck Street Lebanon, Pa 17042 July 9, 1999 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: LEBANON MAGNETIC IMAGING Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9' Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: a2 l / 91;-2 PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Lebanon Magnetic Imaging ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY 192-42-4663 DATE OF BIRTH: 6/2150 TINA V. ROSSON, PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999.03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: Lebanon Magnetic Imaging .vCm.. You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Lebanon Magnetic Imaging, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Ion AT Harrisburg Hospital 101 South Front Street Harrisburg, PA 17101 301 MARKET STREET - 9-'FLOOR P.O. BOX 86S HARRISBURG, PA 17108 (7171232-9900 FAX: (717) 236-9119 JAMES G. NEALON, III MATTHEW R. COVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 In Re: Tina Rosson Social Security* 192424663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HARRISBURG HOSPITAL Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATE Dy?y C i ?'' /c? Sl 11 , PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Harrisburg Hospital ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Harrisburg Hospital : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 : CIVIL ACTION -AT LAW : JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009.23 I, Records Custodian for Harrisburg Hospital, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian 301 MARKET STREET • 91' FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 William Polacheck, Jr. M.D. 99 November Drive Camp Hill, Pa 17011 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. in addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, / b? Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 HELEN M. BUFFINGTON, :CIVIL ACTION - AT LAW DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WILLIAM POLACHECK, JR., M.D. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, V Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: 2 it) %% At, ' A d a u Seal of the Court PROTHONOT EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For William Polacheck, Jr., MD ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 19242-4663 DATE OF BIRTH: 612150 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA v NO. 1999.03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: William Polacheck, Jr., M.D. You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE I, Records Custodian for William Poiacheck, Jr., M.D., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Ion 301 MARKET STREET • 9"' FLOOR P.O. BOX 86J HARRISBURG, PA 17108 17171232.9900 FAX: 1717) 236-9119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 McCuen and Associates Physical Therapy 1709 Old Trail Road Etters, PA 17319 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, arbara Baker, Paralegal NEAEON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 : CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: MCCUEN AND ASSOCIATES, PHYSICAL THERPAY, INC. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9m Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: ?r' 19 9 lJ. n Z,; jt PROTHONOTPR'f Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: McCuen and Associates, Physical Therapy, Inc. ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612150 TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03626 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: McCuen and Associates Physical Therapy You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. PURSUANT TO RULE 4009.23 I, Records Custodian for McCuen and Associates Physical Therpay, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian 301 MARKET STREET • 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17109 (717) 232.9900 FAX: (717) 236-9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Robert Zuckerman, M.D. 2151 Linglestown Road Harrisburg, Pa 17110 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal) NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ROBERT ZUCKERMAN, M.D. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9h Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Robert Zuckerman, MD ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2150 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Robert Zuckerman, M.D. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE I, Records Custodian for Robert Zuckerman, M.D., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian neat®n ..?C r ATTORNEYS AT LAW George Kunkle, M.D. 2405 Linglestown Road Harrisburg, PA 17110 July 9, 1999 In Re: Tina Rosson Social Security #: 192-424663 Dear Records Custodian: 701 MARKET STREET • 9"' FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717) 272.9900 FAX: (717) 276.9119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance the records. With such photocopies, i preparing the same, which we will pron enclosed Certificate of Compliance. completed Certificate of Compliance by and the Subpoena withdrawn. of the deposition date send us photocopies of lease include your statement for the cost of ptly pay. In addition, you must complete the Jpon receipt of such photocopies and the this office, your appearance will be canceled Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE A009.22 TO: GEORGE KUNKLE, M.D. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Neaion 8 Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9'^ Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:2 I W LU 02- Seal of the Court PROTHONOTARY EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: George Kunkle, MD ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY 192-42-4663 DATE OF BIRTH: 612160 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: George Kunkle, M.D. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for George Kunkle, M.D., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian salon 301 MARKET STREET • 9" FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Stephen Fisher, D.M.D. 3825 Linglestown Road Harrisburg, PA 17110 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, v Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: STEPHEN FISHER, DMD Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 90 Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 91" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: 1 A Z, . Ol . /l G ?- PROTHONOTARY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For Stephen Fisher, DMD ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Stephen Fisher, M.D. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION • AT LAW : JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Stephen Fisher, M.D., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian N ealofn -, ATTORNEYS AT LAW July 9, 1999 Michael Red, D.M.D. 11 Flowers Drive Mechanicsburg, PA 17055 In Re: Tina Rosson Social Security #: 192-424663 Dear Records Custodian: 301 MARKET STREET - 9"' FLOOR P.O. BOX 863 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 2369119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER]. KNIGHT You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: MICHAEL REED, DMD Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, gm Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9" Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED: eu? ?f 99 l.r_, /e'e'412=L PROTHONOTARY'/ Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Michael Red, DMD ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CAPE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Michael Red, D.M.D. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION • AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Michael Red, D.M.D., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Nealon AMM YS AT LAW St. Joseph Riverside Hospital Warren, OH 301 MARKET STREET • 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232-9900 FAX: (717236.9119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ?cl V Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ST. JOSPEH RIVERSIDE HOSPITAL Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9" Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: /9 C/ l 2 , . PROTHONOTAR41 Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For St. Joseph Riverside Hospital ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: St. Joseph Riverside Hospital You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. I, Records Custodian for St. Joseph Riverside Hospital, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on been produced. DATE: Records Custodian Nealon ??l6over 301 MARKET STREET • 9^' FLOOR P.O. BOX 86S HARRISBURG, PA 17108 (717) 232.9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Dr. Robert Heckel 3915 E. Market Street Warren, OH 44484 In Re: Tina Rosson Social security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal / BJB/bjb NEALON & GOVER Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR. ROBERT HECKEL Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, P Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED 2 S-' 19 Seal of the Court <',, " AP eL?4 12.1 PROTHONOTAR 'O EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Dr. Robert Heckel ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: UP to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612/60 ali? TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT TO: Dr. Robert Heckel : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE I, Records Custodian for Dr. Robert Heckel, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Nealon ?• wover AM RANI AT LAW Holy Spirit Hospital 503 N. 2181 Street Camp Hill, PA 17011 301 MARKET STREET • 9" FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717(232.9900 FAX: (717) 236-9119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Gt,LG` ?Gl-?.?? Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon 8 Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: s r 0111 &L„' Ge Ay?c,b. i PROTHONOT YJ Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Holy Spirit Hospital ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY 192-42-4663 DATE OF BIRTH: 6/2/60 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Holy Spirit Hospital IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. I, Records Custodian for Holy Spirit Hospital, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian 301 MARKET STREET • 9- FLOOR P.O. BOX 865 HARRISBURG, PA 17106 (717) 232-9900 FAX: (717) 236.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Moffat, Pease and Lim Associates 1000 N. Front Street Wormleysburg, PA 17043 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal BJB/bjb NEALON & GOVER Enclosures TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1999-03625 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY P rRWANT TO RULE enno 22 TO: MOFFIT, PEASE AND LIM ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9% Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9'h Floor Harrisburg, PA 17101 717.232-9900 Attorney for Defendant BY THE COURT: DATED:q r Seal of the Court PROTHONOTAR EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Moffit, Pease and Lim Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 6/2/50 TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION • AT LAW JURY TRIAL DEMANDED rjl, • L TO: Moffit, Pease and Lim Associates You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. I, Records Custodian for Moffit, Pease and Lim Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on been produced. DATE: Records Custodian Nealon `?IGsvlftr July 9, 1999 KDV Orthopedics and Rehabilitation 908 South George Street York, PA 17403 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: 301 MARKET STREET • 9" FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 2329900 FAX: (717) 236-9119 JAMES G. NEALON. III MATTHEW R. COVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal BJB/bjb NEALON & GOVER Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 HELEN M. BUFFINGTON, CIVIL ACTION - AT LAW DEFENDANT : JURY TRIAL DEMANDED SUEtPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: KDV ORTHOPEDICS AND REHAB Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, gm Floor, Harrisburg, PA 17101, 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: James G. Nealon, III, Esquire 301 Market Street, 91° Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED:,., , ? - i g It 9 _ Seal of the Court PR THONOTARY EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: KDV Orthopedics and Rehab ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY 192-42.4663 DATE OF BIRTH: 612/5o TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED NOTICE TO: KDV Orthopedics and Rehabilitation You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for KDV Orthopedics and Rehabilitation, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian 301 MARKET STREET, 9n' FLOOR P.O. BOX 865 HARRISBURG, PA 17108 (717) 232.9900 FAX: (717( 2369119 JAMES G. NEALON, III MATTHEW R. DOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Riverside Associates 3601 N. Progress Avenue Harrisburg, PA 17110 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal BJB/bjb NEALON & GOVER Enclosures TINA V. ROSSON, PLAINTIFF v. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03626 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: RIVERSIDE ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: Lhu, ? 2 S o g g r'PROTHONOTARW Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Riverside Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612/50 e" v =m TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Riverside Associates : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 CIVIL ACTION • AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Riverside Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian salon 301 MARKET STREET • 9"' FLOOR P.O. BOX 865 HARRISBURG, PA 17108 171711519900 FAX: (717) 156.9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY CHRISTOPHER J. KNIGHT July 9, 1999 Goldman and Associates 4700 Union Deposit Road Harrisburg, PA 17111 In Re: Tina Rosson Social Security #: 192-42-4663 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures TINA V. ROSSON, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-03625 CIVIL ACTION - AT LAW HELEN M. BUFFINGTON, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: GOLDMAN AND ASSOCIATES Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9m Floor, Harrisburg, PA 17101. 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: James G. Nealon, III, Esquire 301 Market Street, 9' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED! 1 W- 9S C r ( r, 4-) ". PROTHONOT RY Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Goldman and Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: Up to and Including the Present SUBJECT: Tina Rosson SOCIAL SECURITY #: 192-42-4663 DATE OF BIRTH: 612150 r 4:'P ?p TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT TO: Goldman and Associates : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999.03825 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Goldman and Associates, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian TINA V. ROSSON, PLAINTIFF V. HELEN M. BUFFINGTON, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-03625 : CIVIL ACTION - AT LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Helen M. Buffington, 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. Date: 6/18/99 • JIII, Esquir Attorney for the Defendant t CERTIFICATE OF SERVICE AND NOW, this 9th day of July, 1999, 1 hereby certify that I have served the foregoing Certificate Prerequisite to Service of a Subpoena on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Richard F. Maffett, Jr. 2201 North 2nd Street Harrisburg, PA 17110 James G. Nealon, III, Esquire Ci; C" l'1: s -> tn Li I .1 1lL i? m ? C li ij N CD ¢ N 0 0 o o Q < a m N u < F to 1x ?t! < Y I y xo } Z W f 0 2 N Q N a O W J y 0 W a a I 0 r x U'. .Q { L Z a < < m ? p N 1 it m < I w«w?m •,wwiu•nruo•?a-eum .on mu. ?w ?rr.w?vnwn.unrm u norvwo v Iron una?r• MAFFETT Er ASSOCIATES By: Richard F. Maffett, Jr., Esquire ID #35539 2201 North Second Street Harrisburg, PA 17110 717-233-4160 TINA V. ROBSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IF HELEN M. BUFFI Defendant NO. 99-3625 CIVIL ACTION - LAW JURY TRIAL DEMANDED IMPORTANT NOTICE TO: HELEN M. BUFFINGTON, Defendant %James G. Nealon, III, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17110 DATE OF NOTICE: March 30, 2001 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER 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. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Ri6hard F. Maffett, Jr., Esq. CERTIFICATE OF SERVICE The undersigned hereby certifies that he served a true and correct copy of the foregoing Notice of Default upon counsel of record by depositing same in the United States Mail, postage prepaid, addressed as follows: James G. Nealon, III, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17110 Dated: /L VI J, Richard F. Maffet, , JJ ? n ti `'? . o: c !.{i •__ ? ?? U TINA V. ROSSON, Plaintiff, V. JESSICA RENEE FEGAN, Defendant. TINA V. ROSSON, Plaintiff, V. HELEN M. BUFFINGTON, Defendant. TINA V. ROSSON, Plaintiff, V. HEATHER McKEITHAN, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 97-4289 CIVIL ACTION - LAW JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 99-3625 CIVIL ACTION - LAW JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA NO.: 96-SI-04222-01 CIVIL ACTION - LAW JURY TRIAL DEMANDED RESPONSE OF DEFENDANT HELEN M. BUFFINGTON TO PLAINTIFF'S MOTION FOR COORDINATION AND JOINDER OF ACTIONS IN DIFFERENT COUNTIES PURSUANT TO PA.R.C.P. 213.1 AND IN THE SAME COUNTY PURSUANT TO PA.R.C.P. 213 Admitted. 2.-3. After reasonable investigation, Defendant is without sufficient knowledge or information to form an opinion regarding the truth of the averments contained in Paragraphs 2 and 3 of the Motion and proof thereof is demanded. 4. Admitted. 5. Admitted. 6. It is admitted that the Rosson v. McKeithan matter remains active. After reasonable investigation, Defendant is without sufficient knowledge or information to form an opinion regarding the averment that discovery is not yet completed and proof thereof is demanded. 7. Admitted. 8. Denied. The impact between the Buffington and Rosson vehicle was minor and produced little or no damage to either vehicle. It is specifically denied that the impact could have caused any injury to the Plaintiff. 9. It is admitted that as of May 15, 1995, Plaintiff was treating with Dr. Stouffer and Dr. Zabinski. After reasonable investigation, Defendant is without sufficient knowledge or information to form an opinion as to the averment that the treatment was related to the September 15, 1994 accident. By way of further averment, Plaintiff has a substantial prior history that may be causing all of the Plaintiffs problems. 10. Denied. It is specifically denied that any treatment after May 15, 1995 was related to the May 15, 1995 automobile accident. 11. Admitted. 12. Admitted. 13. Admitted. 14. Admitted. 15. Admitted. 2 16. After reasonable investigation, Defendant is without sufficient knowledge or information to form an opinion regarding the truth of the averments contained in Paragraph 16 of the Motion and proof thereof is demanded. 17. After reasonable investigation, Defendant is without sufficient knowledge or information to form an opinion regarding the truth of the averments contained in Paragraph 17 of the Motion and proof thereof is demanded. 18. Admitted. 19. It is admitted that pursuant to Pa.R.C.P. 213.1(c)(d)(2), that this Honorable Court may order that the case pending in York County captioned Tina V. Rosson v. Heather McKeithan be transferred to Cumberland County for coordinate proceedings with the other two actions filed by Tina Rosson. It is specifically denied that coordination and consolidation would be appropriate. On the contrary, Plaintiff has presented no evidence that her doctors cannot differentiate her injuries between the various accidents. In addition, consolidation would prejudice the rights of the Plaintiff in that the Plaintiff would not be required to establish what injuries are related to each accident. 20. It is admitted that Pa.R.C.P. 213(1)(e)(1) authorizes this Court to order joint trials of pending matters. For reasons stated in Paragraph 19 above, consolidation is not appropriate. 21. Denied. It is specifically denied that consolidation and coordination would be appropriate in this matter. 3 22, Denied. It is specifically denied that the actions involve common questions of law and fact. For instance, the Rosson v. Buffington matter does not involve issues as to the nature and extent of the Plaintiffs injuries and compensation to be received in the Rosson v. Fegan matter. Rather, the sole issue in the Rosson v. Buffington matter is what injuries are causally related to the accident. 23. After reasonable investigation, Defendant is without sufficient knowledge or information to form an opinion regarding the truth of the averments contained in Paragraph 23 of the Motion and proof thereof is demanded. 24. Denied. For reasons stated above, consolidation and coordination is not appropriate. 25. Denied. For reasons stated above, consolidation and coordination is not appropriate. 26. Denied. For reasons stated above, consolidation and coordination is not appropriate. 27. Denied. Any cost to the Plaintiff is as a result of her decision to file suit on account of the three different accidents. 28. Denied. Each jury could be properly instructed and an appropriate measure of damages awarded in each case. 4 29. Denied. Even if the actions are not consolidated, each case will be settled, if appropriate, on the merits of that case. Date: y 1 0 / Respectfully submitted, NEALON & GOVER, P.C. By:? James G. Nealon, III, Esquire I.D. M 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 5 CERTIFICATE OF SERVICE AND NOW, this 11" day of April, 2001, 1 hereby certify that I have served the foregoing RESPONSE TO MOTION FOR COORDINATION AND JOINDER on the following by hand delivery addressed to: Michele J. Thorp, Esquire THOMAS, THOMAS & HAFER, LLP 305 North Front Street, Sixth Floor P.O. Box 999 Harrisburg, PA 17108 Richard F. Maffett, Jr., Esquire MAFFETT & ASSOCIATES 2201 North Second Street Harrisburg, PA 17110 Michael B. Scheib, Esquire GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS 110 South Northern Way York, PA 17402 1 James G. Nealon, III, Esquire 0 ?0^- W<3 W 08-' ?`> o ¢ i r u 'n W ` > I rc zz Z o Z = a Q N R U J W 0 Q Q 4 1 z J ° m Q ?yf a i a u Z N 2 NM11110 •AbAl10•KYfI(0•m'iftla 'on nN01 ]NI'nNMIYNYl1W yY1t'ITY fU MOnNN1 V'Mrll )IYIA TY TINA V. ROSSON, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. V. HELEN M. BUFFINGTON, Defendant. NO.: 99-3625 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER 1.-17. Paragraph 2 is admitted; it is further admitted that on May 15,1995, at approximately 2:15 p.m., the Plaintiff was operating a motor vehicle on 17th Street, at its intersection with Hummel Avenue, Camp Hill, Pennsylvania; it is further admitted that at that time and place, Defendant was operating a motor vehicle in the same direction as the Plaintiff and that the Defendant's vehicle came in contact with the rear of the Plaintiffs vehicle; the remaining averments contained in Plaintiffs Complaint are denied pursuant to Pa.R.C.P. 1029(e). Respectfully submitted, Date: I/ - 16 - 0/ NEALON & GO C. By: James G. Nealon, III, Esquire I. D. #: 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 I, Helen M. Buffington, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Dated: elen M. u fingt CERTIFICATE OF SERVICE AND NOW, this k?day of April, 2001, 1 hereby certify that I have served the foregoing ANSWER on the following by facsimile and by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Richard F. Maffett, Jr., Esquire MAFFETT & ASSOCIATES 2201 North Second Street Harrisburg, PA 17110 717/233-2342 (Fax) James G. Nealon, III, Esquire 0 z n O W 1 Q F < O o (?ga 2> N l? < > I z Z o i I a O N Q Q J W 0 Z Q 4 W u < p N Z N < Q I WAMIIO•AOTl10•Ab110•fY'I1110 ?OMWWf ]NI T/NdpMYllMI?llYL'1T/ f9 NORWO Y'MJ1111Y1f11Y TINA V. ROSSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 97-4289 CIVIL CIVIL ACTION - LAW JESSICA RENEE FEGAN, Defendant JURY TRIAL DEMANDED TINA V. ROSSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 99-3625 CIVIL CIVIL ACTION - LAW HELEN M. BUFFINGTON, Defendant JURY TRIAL DEMANDED TINA V. ROSSON, IN THE COURT OF COMMON PLEAS OF Plaintiff YORK COUNTY, PENNSYLVANIA VS. 96-SI-04222-01 CIVIL ACTION - LAW HEATHER MCKEITHAN, Defendant JURY TRIAL DEMANDED IN RE: MOTION FOR COORDINATION AND JOINDER OF ACTIONS IN DIFFERENT COUNTIES PURSUANT TO PA.R.C.P. 213.1 AND IN THE SAME COUNTY PURSUANT TO PA R C P 213 ORDER AND NOW, this /2 0 day of April, 2001, following argument thereon, the motion of the plaintiff for Coordination and Joinder of Actions in Different Counties pursuant to Pa.R.C.P. 213.1 is GRANTED. It is directed that the above matters be consolidated for trial. The action pending in York County, Pennsylvania, at 96-SI-04222-01 shall he transferred to Cumberland County as part of the implementation of this order. Notice of this transfer shall be given to the York County Prothonotary by counsel for the plaintiff. The costs of transfer, if any, shall be paid by the plaintiff. Richard F. Maffett, Jr., Esquire For the Plaintiff Michele J. Thorp, Esquire For Defendant Fegan James G. Nealon, III, Esquire For Defendant Buffington Michael B Scheib, Esquire For Defendant McKeithan BY THE COURT, Kevin . Hess, J. Am MAFFETT Er ASSOCIATES By: Richard F. Maffett, Jr., Esquire #ID #36639 2201 North Second Street Harrisburg, PA 17110 717-233-4160 Attorneys for Plaintiff TINA V. ROBSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v HELEN M. BUFFINGTON, Defendant NO. 99-3625 CIVIL ACTION - LAW PRAECX TO THE PROTHONOTARY OF SAID COURT: Please mark the above-captioned matter settled and discontinued with prejudice. Dated: September 20, 2001 Richard F. Maffett, ., /Esq. L L-J _ C/D i -' U