HomeMy WebLinkAbout99-03744C3
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CHERI SPIGELMYER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 3>1/q
GOLDEN CORRAL CORPORATION,
d/b/a GOLDEN CORRAL,
Defendant : JURY TRIAL DEMANDED
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice
are served, by entering a written appearance personally or by attorney and filing in writing
with the Court your defenses or objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the court without further notice for any money claimed in the complaint or for
any other claim or relief requested by the Plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
' ^----•.. r --# Administrator
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE PA 17013
(717) 249 3166 or 1 800 990 9108
CHERI SPIGELMYER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : No.
GOLDEN CORRAL CORPORATION,
d/b/a GOLDEN CORRAL,
Defendant : JURY TRIAL DEMANDED
NOTICIA
Le ban demandado a usted en la carte. Si usted quiere defenderse de estas
demandas expuestas en las paginas signuientes, usted tiene vienta (20) dias de plazo at partir
de al fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en
persona a por abogado y archivar en la corte en forma escrita sus defensas o sus objectiones
a has demandas en contra de su persona. Sea avisado que si usted no se fefiende, la carte
tomara medidas y puede una Orden contra usted sin previo aviso o notificacion y por cualquier
queja o akuvui que es pedido en la peticion de demanda. Usted puedo parder dinero o sus
propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO
TIENE ABOGADO O SI NO TIENE EL DIMERO SURCIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELEPONO A LA OFICINA CUYA
DIRECCION SE EMCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSSGUTA ASISTENCIA LEGAL.
Cumberland County Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, PA 17013
Telephone (717) 240-6200
Afs/complaints/spigelmyer
CHERI SPIGELMYER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 5i'9- 37yY &,,a
j r
GOLDEN CORRAL CORPORATION,
d/b/a GOLDEN CORRAL,
Defendant : JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the Plaintiff, CHERI SPIGELMYER, by and through her attorneys,
HANDLER, HENNING & ROSENBERG, by James R. Carroll, Esquire, and makes the within
Complaint against Defendant, GOLDEN CORRAL CORPORATION, d/b/a GOLDEN CORRAL,
as follows:
Plaintiff, Cheri Spigelmyer, is an adult individual, currently residing at 83 A Red Mill
Road, Etters, Cumberland County, Pennsylvania 17319.
2. Defendant, Golden Corral Corporation, is a corporation with a registered address c/o
CT Corporation, 1635 Market Street, Philadelphia, Philadelphia County, Pennsylvania, 19103.
3. At all times material hereto, Golden Corral Corporation was in ownership, control,
management, and possession of the premises known as Golden Corral, located at 6476 Carlisle Pike,
Mechanicsburg, Cumberland County, Pennsylvania, 17055. (Hereinafter the Premises).
4. At all times material hereto, Plaintiff, Cheri Spigelmyer, was a business invitee upon
the premises of Defendant, Golden Corral.
5. At all times material hereto, an employee of Golden Corral had mopped the floor at
the premises, near the cash register, allowing it to remain in a wet and slippery condition.
6. At all times material hereto, there were no warning signs posted on the Premises
warning of the water or the wet, slippery condition that remained on the floor.
7. On or about June 25, 1997, Plaintiff, Cheri Spigelmyer was walking across the tile
floor at the Premises near the cash register, when she slipped on a wet, slippery condition, and was
caused to fall to the floor.
8. The slip and fall caused Plaintiff, Cheri Spigelmyer, to suffer extreme pain to her left
knee and back.
9. At all times material hereto, Plaintiff, Cheri Spigelmyer, believes and therefore avers
that Defendant, Golden Corral Corporation, was responsible for maintaining the safe condition of
the property known as the Golden Corral.
10. The occurrence of the aforesaid incident and the injuries to the Plaintiff, Cheri
Spigelmyer, resulting therefrom, were caused directly and proximately by the Defendant's
negligence, generally and more specifically as set forth below:
(a) In causing or permitting the floor of the common area at the Premises to
remain covered with water, or in a wet slippery condition, thereby posing an
unreasonable risk of injury to the Plaintiff and to other persons lawfully upon
the premises;
(b) In failing to make reasonable inspection of said Premises which would have
revealed the existence of the dangerous condition posed by the water, or wet
and slippery condition thereby allowing the same to be and remain a
dangerous condition when the Defendant knew or should have known of it;
(c) In failing to ensure that the common path near the register of said Premises
was maintained in a safe condition to prevent injury to the Plaintiff and other
persons lawfully upon said premises;
(d) In failing to post a warning sign or device in the area to notify customers of
the dangerous slippery and wet condition on the floor of said Premises;
3
(e) In failing to dry the water or wet slippery condition from the floor of said
Premises so as to avoid the situation in which the Plaintiff slipped and fell;
and
(f) In failing to maintain the common floor area in a reasonably safe condition
that would prevent a customer from slipping and falling.
H. Defendant had actual knowledge or should have known through the exercise of
ordinary care and diligence that there was a slippery, wet condition in the area where the Plaintiff,
Cheri Spigelmyer, slipped and fell.
12. As a direct result of the Defendant's negligence, Plaintiff, Cheri Spigelmyer,
sustained serious injuries including but not limited to, her back, left knee, neck, heel spur syndrome,
and a herniated disc.
13. As a result of the negligence of the Defendant, Plaintiff, Cheri Spigelmyer, has
undergone great physical pain, discomfort, and mental anguish, and she will continue to endure the
same for an indefinite period of time in the future, to her great and loss, physically, emotionally and
financially.
4
14. As a result of the negligence of the Defendant, Plaintiff, Cheri Spigelmyer, has been
and probably will in the future be hindered from attending to her daily duties to her great detriment,
loss, humiliation and embarrassment.
15. As a result of the Defendant's negligence, Plaintiff, Cheri Spigelmyer, has and
probably will in the future suffer a loss of life's pleasures.
16. As a result of the Defendant's negligence, Plaintiff, Cheri Spigelmyer, has and
probably will in the future suffer lost wages/income.
17. Plaintiff, Cheri Spigelmyer, believes and therefore avers that her injuries are
permanent in nature.
18. As a result of the Defendant's negligence, Plaintiff, Cheri Spigelmyer, has been
compelled in order to effect a cure for the aforesaid injuries, to expend large sums of money for
medicine and medical attention, and will be required to expend large sums of money for the same
purposes in the fixture, to her great detriment and loss.
5
WHEREFORE, Plaintiff, Cheri Spigelmyer, seeks damages from the Defendant, Golden
Corral, in an amount in excess of twenty-five thousand dollars ($25,000.00), and demands a trial by
jury.
Respectfully Submitted,
HANDLER, HENNING
& ROSENBERG
Date: 6 (l W n By:
I.D/No. 75985
3 Market Street
P.O. Box 1177
Harrisburg, PA 17108
(717) 238-2000
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the preceding documents are true and correct to the best
of my knowledge, information and belief. I understand that false statements made herein are subject
to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.
Date .n
Cheri Spigelmyer?
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CHERI L. SPIGELMYER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
CIVIL ACTION -LAW
NO. 99-3744
JURY TRIAL DEMANDED
Defendant.
PRAECIPE FOR APPEARANCE ON BEHALF OF DEFENDANT
Kindly enter the appearance of Edward E. Knauss, IV, Esquire, on behalf of the
Defendant Golden Corral Corporation, d/b/a Golden Corral, in the above-captioned matter.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
Edward E. Knauss, IV, Esquire
Attorney I.D. No. 19199
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: -112I-fl
CERTIFICATE OF SERVICE
I, Edward E. Knauss, IV, Esquire, do hereby certify that on the date set forth
below, I did serve a true and correct copy of the foregoing document upon the following
person(s) at the following address(es) indicated below by sending same in the United States
Mail, first-class, postage prepaid:
James R. Carroll
Handler, Henning & Rosenberg
319 Market Street
P. O. Box 1177
Harrisburg, PA 17108
Attorney for Plaintiff
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
Edward E. Knauss, IV, Esquire
Dated: '7 Z?- 1 r
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CHERI L. SPIGELMYER,
Plaintiff,
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3744
JURY TRIAL DEMANDED
ANSWER OF DEFENDANT TO THE COMPLAINT
1. Admitted.
2. Admitted.
3. Denied. It is denied that Golden Corral Corporation owned, controlled,
managed or possessed the premises known as Golden Corral at the stated location.
4. Denied, and in further answer thereto the preceding Paragraph 3 is incorporated
herein by reference.
5. Denied, and in further answer thereto the preceding Paragraph 3 is incorporated
herein by reference.
6. Denied. All warning; signs that were necessary would have been posted. It is
denied that there was water on the floor, or that the conditions were wet and slippery.
7. Denied.
8. Denied.
9. Denied. Defendant Golden Corral Corporation was not responsible for
maintaining the premises. In further answer thereto, the premises were maintained in a safe
condition.
10. Denied. All subparagraphs (a) through (f) are denied.
11. Denied.
12. Denied.
13. Denied.
14. Denied.
15. Denied.
16. Denied.
17. Denied.
18. Denied.
WHEREFORE Defendant demands that the Complaint be dismissed and that judgment
be entered in its favor with costs.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Edward E. Knauss, IV, Esquire
Attorney I.D. No. 19199
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
D 7
ated:
-??
07/02/99 13:43
V O ATTON
?o,4 Y I C. I 0 I V 1 U Y do hereby verify that the Fat is set fottlt
in the foregoing Answer are true and cormt?the test of my personal knowledge or
information and belief. I understand that false statements herein are trade subject to the
penalties of 18 Pa.C.S. 14904, relating to unswom falsification to authorities.
Date: 1I Ce I6I
$717 234 9479 d"W', "06. rA
priz ? Q 4
CERTIFICATE OF SERVICE
I, Edward E. Knauss, IV, Esquire, do hereby certify that on the date set forth
below, I did serve a true and correct copy of the foregoing document upon the following
person(s) at the following address(es) indicated below by sending same in the United States
Mail, first-class, postage prepaid:
James R. Carroll
Handler, Henning & Rosenberg
319 Market Street
P. O. Box 1177
Harrisburg, PA 17108
Attorney for Plaintiff
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:?'l_ w ?-
/ / Edward E. Knauss, IV, Esquire
Dated: -7 fl y
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03744 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SPIGELMYER CHERI
VS.
GOLDEN CORRAL CORP ET AL
CHRISTOPHER EVANS , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT, PLTFFIS was served
upon GOLDEN CORRAL CORPORATION D/B/A GOLDEN CORRAL the
defendant, at 9:30 HOURS, on the 24th day of June
1999 at 6746 CARLISLE PIKE
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to RICHARD CURTAIN (MANAGER)
a true and attested copy of the NOTICE AND COMPLAINT, PLTFF'S
together with REQUEST FOR PRODUCTION OF DOCUMENTS, PLTFF'S
FIRST SET OF INTERROGATORIES
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answer
Docketing 18.00
Service 6.20
Affidavit // !!
Surcharge 8.00 omas ine, ri
DL R HENNING & ROSENBERG
07/26 1b99
by C% - G
?jjuuy Sn?rj
Sworn and bscribed o before me
this /_?day of l tt5
% SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-03744 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SPIGELMYER CHERI
VS.
GOLDEN CORRAL CORP ET AL
R. Thomas Kline , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: GOLDEN CORRAL CORPORATION
D/B/A GOLDEN CORRAL
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of PHILADELPHIA County, Pennsylvania.
to serve the within NOT & COMP, REQ FOR PROD, INTE
On July 26th, 1999 , this office was in receipt of
the attached return from PHILADELPHIA County, Pennsylvania.
Sheriff's Costs: So answe s:
Docketing 6.00 /
Out of County 9.00
Surcharge 8.00 t? I' omas ine, S eri
Dep. Phila Cc 116.00
$135-U0' 07 DLL$R§9HHENNING & ROSENBERG
Sworn and'/subscribed o befor me
this ?? r day of U 5
SHERIFF'S RETURN - SUMMON COMPLAINT
COMMON PLEAS EL m Lft= COUNTY COURT
S?
NO. VERSUS
TERM, 19
/9
n n ? Defendant
SERVED AND MADE KNOWN TO AQO? Qa=-F S.Defendant Company
by handing a true and attested copy of the within Summons omplafn issued in the above captioned matter
on l 19 - ?5- , at a o'clock, 29 M., E.S.T.
at // (to 3S AI it k466 "t- Tr in the County of Philadelphia,
State of Pennsylvania, to Sl9 F179A 5-6COA HAJ
? (1) the aforesaid defendant, personally;
? (2) an adult member of the family of said defendant, with whom said defendant resides, who stated that
his/her relationship to said defendant is that of
? (3) an adult person in charge of defendant's residence; the said adult person having refused, upon re-
quest, to give his/her name and relationship to said defendant;
? (4) the manager/clerk of the place of lodging in which said defendant resides;
? (5) agent or EEG for the time being in charge of defendant's office or usual place of business.
0 (6) the EEG ( 5TEM . I .end-ofiicac.of said defendant Company;
So Answers,
JOHN a. GREEN, Sheriff
fay:
Deputy Sherill
12.25 (R,r. 12,07)
4u1 1 Si4 iD'ul: U? '?ElAl rr o '-uInzp'CCanz i)riJlwc? i'enn i','111.a 11
Cheri Spigelmyer
vs.
Golden Corral Corporation, d/b/a Golden Corral
No. 99-3744 Civil 19
Now, 6/22/99 19_, r SHERIFF OF CUMBERLAND COUNTY, PA do hereby deputize the Sheriff of
Philadelphia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, Pa.
Affidavit of Service
Now,
at
by handing to
attested copy of the original
the contents thereof.
Sworn and subscribed before
me this day of _
19 , at
o'clock N, served the
So answers,
Sheriff of
COSTS
SERVICE S
19 MILEAGE
AFFIDAVIT
County, Pa.
a true and
and made known to
e
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-3744
GOLDEN CORRAL CORPORATION CIVIL ACTION - LAW
d/b/a GOLDEN CORRAL,
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Document #: / 9154?./
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:.??%G?CL?G ?- _
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: _ / 9 o
T- I
Dxwnent N: 1915411
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGEER, WICKERSHAM, KNAUSS & ERB, P.C.
By: U?e???%Jy
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: 111.LyLoo
Da menf M.: 1915471
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that 1 served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this ? day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heal er L. Harbaugh, Esquire
Da Merv N.: 191342.1
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 400912
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-3744
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Trent Nichols, M.D.
195 Stock Street
Suite 203
Hanover, PA 17331
Within twenty (20) days after service of this
following documents or things: any and all r
3211 North Front Street. Harrisburg. PA 17110.
you are ordered by the court to produce the
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date: BY
(Prothonotary)
Seal of the Court
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Document B.' 191520.1
CHERI L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE
TO: Custodian of Medical Records
Trent Nichols, M.D.
195 Stock Street
Suite 203
Hanover, PA 17331
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,
of my knowledge, information and belief that
pursuant to the subpoena issued on
Date:
(person served with subpoena) certify to the best
all documents or things required to be produced
(date of subpoena) have been produced.
Person served with subpoena
Document #: 191542. /
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CHERI L. SPIGELMYER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
GOLDEN CORRAL CORPORATION CIVIL ACTION - LAW
d/b/a GOLDEN CORRAL,
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Docwneni N: 191342.1
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:?_? P
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: j//0
Oowmeni N: 191542.1
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:Q?/ate.-G? f?
Heather L. Harbaugh, Esquire
/
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: A&/-00)
Document N: /9/542./
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law finn of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this 4 day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
Document N.: 191541.1
SUBPOENATO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
To: Custodian of Medical Records
John Gilfert, PM
33600 Trindle Road
Camp Hill, PA 17011
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: any and all records of whatsoever nature relating to the treatment of
Cheri L. Sniaelmver. D.O.B. 10/16/64. from the start of vour treatment uD to the Dresent time. This
should include, but not be limited to, all correspondence, office notes, handwritten notes, charts,
records, reports, studies, correspondencetreports from other treating physicians, x-rays nurses notes,
hospital records, x-rav studies, billing records. etc. at Metzger. Wickersham. Knauss & Erb. P.C..
3211 North Front Street. Harrisburg. PA 17110.
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
BY
(Prothonotary)
Seal of the Court
CHERI L. SPIGELMYER,
Plaintiff
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
TO: Custodian of Medical Records
John Gilfert, PM
3600 Tindle Road
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - 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 (person served with subpoena) certify to the best
s required to be
of my knowledge, information and belief that all documents
of subpoena) have been produced.d
pursuant to the subpoena issued on ?-
Date:
Person served with subpoena
Document 4. 19154:.1
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CHERI L. SPIGELMYER,
V.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99.3744
GOLDEN CORRAL CORPORATION
d/b/n GOLDEN CORRAL,
Defendant
CIVIL ACTION - LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Document 4: 1915423
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By: &V?/L' C ( _
Bather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: 9
Document 9: 191S42 /
CHERI L. SPIGELMYER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:?/????C?
Bather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated:
! Y Da
Document N: 191547./
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant ?to, Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
Document N: l9/541./
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Thomas Malin, M.D.
99 November Road
Camp Hill, PA 17011
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date: BY
(Prothonotary)
Seal of the Court
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Thomas Malin, M.D.
99 November Road
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - 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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
D(wwnent N' 1915423
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CHERI L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Document #. 191542.1
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
I- Bather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: 9 &/
Document N: 191542.1
CHERI L. SPIGELMYER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
57
By:
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated:
/ 4' OD
Document N: 191547.1
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this 47' day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
O
Heather L. Harbaugh, Esquire
Oxumenr N.: /9/3411
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
To: Custodian of Medical Records
William Polachek, M.D.
99 November Drive
Camp Hill, PA 17011
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: any and all records of whats,wva.•..e....e
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fall to produce the documents or things required by this subpoena within twenty (20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
This subpoena was issued at the request of the following person:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
BY
Seal of the Court (prothonotary)
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
William Polachek, M.D.
99 November Drive
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - 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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
Document #: 191542 1
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CHERI L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Document W: l9154Z I
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:? ?!'
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: //2 /D/
Ooomenl Hr 1913421
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:Z A? 7
Heather L. Harbaugh, Esgm
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: GfJ
Da men, p: 191542./
r
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant tole 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this y day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
Document W: 1915411
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Katherine Gallagher, M.D.
4076 Market Street
Camp Hill, PA 17011
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: any and all records of whatsoever nature relating to the treatment of
3211 North Front Street. Harrisburg, PA 17110.
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date:
(Prothonotary)
Seal of the Court
CHERI L. SPIGELMYER,
V.
Plaintiff'
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
TO: Custodian of Medical Records
Katherine Gallagher, M.D.
4076 Market Street
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
C!VIL ACTION - 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, , (person served with subpoena) certify to the best
of my knowledge, information and belief that all documents or things required to be produced
pursuant to the subpoena i< ;ued on _ (date of subpoena) have been produced.
Date:
Person served with subpoena
Dacvmvm p 19/54:.!
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CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION- LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Docmnem g. 191542.1
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By: O?j_ ? ? _ O4
Heather L. Harbaugh, Esquire
=d
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: C //O
/
Document #: 191542.1
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By: Z4&4??"f-
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: /.1/41/00
Da mein N: 191542. 1
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to ?R/ule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this y d y of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
? .._? v
Heat er L. Harbaugh, Esquire T
Document N: /9/311.1
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Alan Roumm, M.D.
650 Poplar Church Road
Camp Hill, PA 17011
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: any and all records of whatsoever nature relating to the treatment of
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date: BY
(Prothonotary)
Seal of the Court
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
TO: Custodian of Medical Records
Alan Roumm, M.D.
650 Poplar Church Road
Camp Hill, PA 17011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - 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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
Document 0: 191541.1
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CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Doaonvn! k 191342.1
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire 14111
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: 0
Document k.: 191541.1
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
Bather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: 4/ Dv
Document N: 191342.1
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that 1 served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to4Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this ! day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
Do mein N: 191542.1
SUBPOENA TO PRODUCE. DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
To: Custodian of Medical Records
Jay J. Cho, M.D.
Rehab Medicine Associates, P.C.
5124 E. Trindle Road
Mechanicsburg, PA 17055
Within twenty (20) days after service of this
following documents or things: anv and all r
you are ordered by the court to produce the
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Coral
BY THE COURT:
Date: BY
(Prothonotary)
Seal of the Court
CHERI L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
TO: Custodian of Medical Records
Jay J. Cho, M.D.
Rehab Medicine Associates, P.C.
5124 E. Trindle Road
Mechanicsburg, PA 17055
No. 99.3744
CIVIL ACTION - 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, , (person served with subpoena) 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 of subpoena) have been produced.
Person served with subpoena
Document: 1915421
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CHERI L. SPIGELMYER,
Plaintiff
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION- LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Danimenl#;19154?./
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:?
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: _I/Z&/
D"ument #: /91541.1
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By: 1 / ' , a ? 1L
Hea er L. Harbaugh, Esgmre
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: J?/C-(/Oy
Document N.: 191542.1
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this v y of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
V.XHeater L. Harbaugh, Esquire
Document N: 19/542.1
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
To: Custodian of Medical Records
Holy Spirit Hospital
503 N 212r Street
Camp Hill, PA 17011-2288
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: any and all records of whatsoever nature relatin to the treatment of
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717)238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date: BY
(Prothonotary)
Seal of the Court
CHERI L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Dm menl #.: 191542. /
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Holy Spirit Hospital
503 N. 215` Street
Camp Hill, PA 17011-2288
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION-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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
Dxumew H: 191347.1
T .
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(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS NA&ERB, P.C.
By:
Heather L. Harbaugh, Esquire
Attomey I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: /h9l0/
Daumenr W: 191542 1
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
Bather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110.0300
(717) 238-8187
Attorney for Defendant
Dated: ?t' DD
Document N: 191541.1
CERTIFICATE OF SERVICE
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant ?to?Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this / day of December.
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
MET%GER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire 100,
Ilrnrornrn! 4 191342 1
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Community General Osteopathic
4300 Londonderry Road
Harrisburg, PA 17109-5317
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or thingst any and all records of whatsoever nature relatine to the treatment of
Cheri L Syieelmyer. DOB 10/16/64 from the start of your treatment up to the present time This
should include, but not be limited to, all correspondence, office notes, handwritten notes, charts
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request ns 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:
Heather L. Harbaugh, Esquire
Attorney I.D. N 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Seal of the Court
BY
(Prothonotary)
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-3744
GOLDEN CORRAL CORPORATION CIVIL ACTION - LAW
d/b/a GOLDEN CORRAL,
Defendant JURY TRIAL DEMANDED
NOTICE
TO: Custodian of Medical Records
Community General Osteopathic
4300 Londonderry Road
Harrisburg, PA 17109-5317
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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
Document 9. 191542.1
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CHERII L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
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 certifies that:
(I) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
11"umem N: 1915421
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By: ti rTi
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: 9 IJ
Dm menr q.: 191542.1
CHERI L. SPIGELMYER,
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
No. 99-3744
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have t%venty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Dated:
By:( /Y
Bather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717)238-8187
Attorney for Defendant
oL ?/
Dmment N. 191541.1
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 400912
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
To: Custodian of Medical Records
Seidle Memorial Hospital
120 S. Filbert Street
Mechanicsburg, PA 17055-6539
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: any and all records of whatsoever nature relating to the treatment of
Cheri i._ Rn:oulmvn.. rich n 1nN ucw r -
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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 sere ag this subpoena may seek a court order compelling you to comply with it.
This subpoena was issued at the request of the following person:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date: BY
Seal of the Court (Prothonotary)
CHERI L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
TO: Custodian of Medical Records
Seidle Memorial Hospital
120 S. Filbert Street
Mechanicsburg, PA 17055-6539
No. 99-3744
CIVIL ACTION - 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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
Dnnnnew N: 191342 1
CERTIFICATE OF SERVICE
1, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this 7 day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Hazbaugh, Esquire
Document N-1915{1.1
s
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o X
55 ? % T
i
r o
CHERI L. SPIGELMYER,
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (20)
days prior to the date on which the subpoena is sought to be served,
(2)
(3)
a copy of the notice of intent, including the proposed subpoena, is attached
to this certificate,
no objection to the subpoena has been received; and
Document M: 1915421
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: IT /D/ _
Document W: 1915!?. /
CHERI L. SPIGELMYER,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
Bather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated:
? oU
Do Menik 1915411
CERTIFICATE OF SERVICE
1, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to Ryle 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this L7 day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
Document M: 191511.1
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
To: Custodian of Medical Records
Grandview Surgery & Laser Center
205 Grandview Avenue, 1" Floor
Camp Hill, PA 17011-1708
Within twenty (20) days after service of this
followine documents or thines: anv and all r
are ordered by the court to produce the
hospital records, x-ray studies, billing records, etc. at Metzger. Wickersham, Knauss & Erb. P.C.,
3211 North Front Street. Harrisbure, PA 17110.
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Hanisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date: BY _
(Prothonotary)
Seal of the Court
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
TO: Custodian of Medical Records
Grandview Surgery & Laser Center
205 Grandview Avenue, 151 Floor
Camp Hill, PA 17011-1708
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - 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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
Document #: 1915421
Fz i c
a ti O0 o
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a E
VI ?
CHERI L. SPIGELMYER,
v.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION-LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Document q' 191342 1
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZ.GER, WICKERSHAM, KNAUSS & ERB, P.C.
By: 0eat C??
r L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated: / 1 0 /
Oavururri? b: 1915421
CHERI L. SPIGELMYER,
Plaintiff
v.
-..- ?:_
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated:
D
Do menl N.:/91542./
I, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this 'r day of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heat rer L. Harbaugh, Esquire
Do menr N: 191541.1
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
To: Custodian of Medical Records
Walter Reed Hospital
6900 Georgia Avenue, NW #77
Washington, DC 20307-0004
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following; documents or things: anv and all records of whatsoever nature rata Hnn fn fhP freafmnnf of
3211 North Front Street. Harrisburg, PA 17110
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Heather L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date: BY
Seal of the Court (Prothonotary)
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE
TO: Custodian of Medical Records
Walter Reed Hospital
6900 Georgia Avenue, NW #77
Washington, DC 20307-0004
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,
of my knowledge, information and belief
pursuant to the subpoena issued on
Date:
(person served with subpoena) certify to the best
all documents or things required to be produced
(date of subpoena) have been produced.
Person served with subpoena
Dn wnenf M: 191542.1
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;oo
n
'O
a d 8 v,
n ?
?? S
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
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 certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty (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
Doa,meu N.: 191342.1
(4) the subpoena which will be served is identical to the subpoena which is
attached to the notice of intent to serve the subpoena.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
Attorney I.D. No. 83997
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated:
Urxnmenr Nr 191542.1
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO
PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.21
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is made, the subpoena may be
served.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:
Heather L. Harbaugh, Esquire /
Attorney I.D. No. 83997
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Defendant
Dated:
Documentk 191141.1
CERTIFICATE OF SERVICE
1, Heather L. Harbaugh, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and correct copy of Defendants Notice of Intent to Serve
a Subpoena to Produce Documents and Things for Discovery Pursuant/too Rule 4009.21 with
reference to the foregoing action by first class mail, postage prepaid, this '12 ay of December,
2000 on the following:
Stephen G. Held, Esquire
Handler Henning & Rosenberg
319 Market Street, P.O. Box 1177
Harrisburg, PA 17108
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Heather L. Harbaugh, Esquire
-
Dmmen M: 191542. /
SUBPOENA TO PRODUCE DOCUMENTS OR
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22
CHERI L. SPIGELMYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GOLDEN CORRAL CORPORATION
d/bla GOLDEN CORRAL,
Defendant
To: Custodian of Medical Records
Hershey Medical Center
500 University Drive
Hershey, PA 17033
No. 99-3744
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: any and all records of whatsoever nature relating to the treatment of
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certification of compliance, to the party making this request as 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:
Headier L. Harbaugh, Esquire
Attorney I.D. # 83997
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
Attorney for Defendant Golden Corral
BY THE COURT:
Date:
BY
(Prothonotary)
Seal of the Court
CHERI L. SPIGELMYER,
V.
Plaintiff
GOLDEN CORRAL CORPORATION
d1b/a GOLDEN CORRAL,
Defendant
TO: Custodian of Medical Records
Hershey Medical Center
500 University Drive
Hershey, PA 17033
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3744
CIVIL ACTION - 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, , (person served with subpoena) 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 of subpoena) have been produced.
Date:
Person served with subpoena
Darnmrm #. 191542.1
T
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CHERI L. SPIGELMYER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : No. 99-3744
GOLDEN CORRAL CORPORATION
d/b/a GOLDEN CORRAL,
Defendant
TO THE PROTHONOTARY:
Jury Trial Demanded
PRAECIPE
Please mark the above-captioned action settled, discontinued and ended.
Dater
HANDLER, HENNING& ROSENBERG, LLP
By: fho
Step I I uire
I.D. # 663
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Attorney for Plaintiff
CERTIFICATE OF SERVICE
AND NOW, thiallp- day of October, 2003,1 hereby certify that I have, on this date,
served the within document upon the Defendant, by sending a true and correct copy of
same to his attorney of record, and including a copy to all parties of interest via first class
United States mail, postage prepaid, and addressed as follows:
Andrew W. Norfleet, Esquire
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
P.O. Box 5300
Harrisburg, PA 17110
HANDLER, HENNING & ROSENBERG, LLP 'tm By: I Y
Dori Beard
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