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HomeMy WebLinkAbout99-07637Li 1 V `C rrc jtx c rV`;! !? e 1 4 April L. Strang-Kutay, Esquire ID 8 46728 GOLDBERG, RATZNAN & SHIPHAN, P.C. P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Fax (717) 234-6810 Attorneys for Plaintiffs GAIL SZOBOSZLAY AND MICHAEL IN THE COURT OF COMMON PLEAS SZOBOSZLAY, HER HUSBAND CUMBERLAND COUNTY, PA Plaintiffs NO. 99 /G 3 / l f ui ? ^?ILJ?? VS. CIVIL ACTION - LAW GEORGE JEFFRIES, III, M.D. & CENTRAL PENNSYLVANIA OBSTETRICS/GYNECOLOGY, INC. JURY TRIAL DEMANDED Defendants PRAECIPE TO THE PROTHONOTARY: Please issue a Writ of Summons against George Jeffries, III, M.D. and Central Pennsylvania Obstetrics /Gynecology, Inc. at 890 Poplar Church Road, Camp Hill, PA 17011 advising them that an action has been commenced against them. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. Apr'1 L. Str g-K y, squi IDff: 46728 P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Plaintiffs /2 zo 9 Date: 0 ? n CJ J Z Commonwealth of Pennsylvania County of Cumberland Gail Szoboszlay and Kichael Szoboszlay, her husband vs. George Jeffries, III, M.D. & Central Pennsylvania Obstetrics/Gynecology, Inc. 890 Poplar Church Road Camp Hill, PA 17011 Court of Common Pleas 99-7637 Civil Term ...... 19____ Vo. ---------------------- ------- Civil -Action----Law _________ I9'' To _George--Jeffries-ZII.,_-MLA-_-&-fx--Dtral Pennsylvania Cbstetrics/Gynecology, Inc You are hereby notified that Gail Szoboszlay_and husband the Plaintiff has commenced an action in ---------- 0X11.AQt;isn_=_ J3W________________________ against you which you are required to defend or a default judgment may be entered against you. (SEAL) Curtis R. Long ------------------------------------------------- Prothonotary fk7 ¢ ?- -- LZlIJ Date ------- DPembrx-2?---------- 19--29 I Deputy w i UU ti i ? D Z ? H ?1 1 ? H ? C a U r' [n ? fz?, a H rni ; ?;`? W ? CL Ul C7 U O 00 .p o i O U W G y co w •r4 N roN C) ?,a o x ty, !may a00 a'H N W co r-I apxya7vc og•ri ul (n N ?C N C O N r m z d THOMAS, THOMAS & FIAFER, LLP By: Peter J. Carry, Esquire ldentifrcation No. 16622 305 North Front Street P. O. Box 999 Harrisburg, PA 17108 (717) 255-7637 Ahoruey for Defeudants GAIL SZOBOSZLAY and : IN THE COURT OF COMMON PLEAS OF MICHAEL SZOBOSZLAY, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : Docket No. 99-7637 Civil Term V. GEORGE JEFFRIES, III, M.D., and CENTRAL PENNSYLVANIA CIVIL ACTION -LAW OBSTETRICS/GYNECOLOGY, INC., Defendants JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Defendants, George Jeffries, III, M.D., and Central Pennsylvania Obstetrics/Gynecology, Inc., in the above-captioned matter. THOMAS & HAFER, LLP PETER J. CUR Pff, SQUIR: Attorney fo efendants CERTIFICATE OF SERVICE 1, Kathy L. Sitter, an employee of the law offices of Thomas, Thomas & Hafer, LLP, do hereby certify that I served the foregoing document upon counsel of record by sending same via United States mail, first class, postage prepaid, as follows: April L. Strang-Kutay, Esquire GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Date: ?C"7tt-u' KATHY I//. SITLER ,- April L. Strang-&utay, Esquire ID B 46728 GOLDBERG, KAT22W & SHIPMAN, P.C. P.O. Box 1268 Harrisburg, PA, 17108-1268 (717) 234-4161 Fax (717) 234-6810 Attorneys for Plaintiffs GAIL SZOBOS ZLA'_' AND MICHAEL IN THE COURT OF COMMON PLEAS SZOBOSZLAY, HER HUSBAND CUMBERLAND COUNTY, PA Plaint iffs vs. GEORGE JEFFRIES, III, M.D. & CENTRAL PENNSYLVANIA OBSTETRICS/ GYNECOLOGY, INC. Defendants NO. 99-7637 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any coney claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dies de plazo al partir de la fecha de la 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 objectiones a las demandas en contra de su persona. Sea adisado que si usted no se defiende, la sin previo aviso o notificacion y por cualquier quja o puede perder dinero o sus propledades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 4 ""31 April L. Strang-Kutay, Esquire ID N 46728 GOLDBERG, KATZMAN & SHIPMAN, P.C. P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Fax (717) 234-6810 Attorneys for Plaintiffs GAIL SZOBOSZLAY AND MICHAEL IN THE COURT OF COMMON PLEAS SZOBOSZLAY, HER HUSBAND CUMBERLAND COUNTY, PA Plaintiffs VS. GEORGE JEFFRIES, III, M.D. & CENTRAL PENNSYLVANIA OBSTETRICS/GYNECOLOGY, INC. Defendants NO. 99-7637 Civil Term CIVIL ACTION - LAW JURY TRIAL, DEMANDED COMPLAINT AND NOW, come the Plaintiffs, Gail Szoboszlay and Michael Szoboszlay, her husband, by and through their attorneys, Goldberg, Katzman and Shipman, P.C., who respectfully represent as follows: 1. That the Plaintiffs are adult individuals, husband and wife, living and residing at 142 Forest Drive, Camp Hill, Pennsylvania 17011. 2. That the Defendant, George Jeffries, III, M.D. (hereinafter referred to as "Dr. Jeffries"), is a physician licensed to practice medicine in the Commonwealth of Pennsylvania with his business address at 690 Poplar Church Road, Suite 503, Camp Hill, Pennsylvania 17011. 3. That the Defendant, Central Pennsylvania Obstetrics/Gynecology, Inc., is a business entity located at 890 Poplar Church Road, Suite 503, Camp Hill, Pennsylvania 17011. 4. That at all times material hereto, Defendant Jeffries was acting as an employee and/or agent of the business entity known as Central Pennsylvania obstetrics/Gynecology, Inc. 5. That on or about November 17, 1998, Plaintiff, Gail Szoboszlay, underwent an abdominal hysterectomy performed by her gynecologic surgeon, Dr. Jeffries, which procedure was designed to address her condition of uterine prolapse. 6. That on the date of November 17, 1998, Gail Szoboszlay was 28 years of age, the mother of three children, and employed as a professional chef. 7. That during the abdominal hysterectomy of November 17, 1998, Dr. Jeffries performed an inadvertent cystotomy during dissection of Ms. Szoboszlay's cervix, which complication was recognized intra-operatively. 8. That as a result of the inadvertent cystotomy created by Dr. Jeffries, Urologist, Dr. Paul Smith was summoned to the operating room and performed a standard two layer closer of the cystotomy using absorbable suture. 2 9. That during Gail Szoboszlay's recuperation in the hospital following her abdominal hysterectomy, she suffered an episode of transient clot retention. 10. That as a result of the inadvertent cystotomy that had been created by Dr. Jeffries during her abdominal hysterectomy, Gail Szoboszlay maintained a catheter in place for approximately two weeks during her recuperative phase. 11. That once the catheter was removed at the instruction of her physician, Dr. Smith, Plaintiff, Gail Szoboszlay, began to experience immediate bladder problems, which, initially, included, but are not limited to, pelvic pain, urinary frequency, dysuria, and urge incontinence. 12. That Gail Szoboszlay remained under the care of Dr. Smith from November 1998 through March 1999 with regard to the above indicated symptoms that, once having begun when the Foley catheter was first removed, continued to progressively worsen over time. 13. That in February 1999, Dr. Paul Smith performed a cystoscopy procedure to inspect Plaintiff's, Gail Szoboszlay's, bladder, and found it to show adequate healing; nevertheless, Plaintiff's symptoms of bladder distress continued to intensify. 14. That while Plaintiff, Gail Szoboszlay, made an attempt to return to her job as a professional chef, on a part-time basis, following her hysterectomy procedure, by January 1999, she was 3 completely unable to work due to severe bladder pain, and the accompanying symptoms described above. 15. That as a result of Gail Szoboszlay's pronounced bladder difficulties, Dr. Smith referred her to be seen by Dr. Deborah Erikson, a urologist at the Hershey Medical Center. 16. Upon Dr. Erikson's evaluation of Gail Szoboszlay in March of 1999, this physician performed a cystometric exam which revealed an unstable bladder, and a bladder capacity of only 60 cc's. 17. That as of March 1999, Gail Szoboszlay was taking the medications Ditropan, as well as Belladonna and opium suppositories. 18. That on March 24, 1999, Dr. Erikson facilitated the performance of a VCUG which demonstrated a bladder capacity of 200 cc's and normal contour of the bladder with a Grade I unilateral vesi.coureteral ref lux; the Plaintiff's post-void residual volume was minimal after the Plaintiff voided in the bathroom following infusion study. 19. That Dr. Erikson, in conjunction with her initial evaluation of Gail Szoboszlay , recommended an MRI of the lumbar spine to rule out any other disease which may have been causing bladder symptoms; the MRI was conducted on April 16, 1999, and was read to be within normal limits. 1 4 20. That Gail Szoboszlay's symptoms continued, unfortunately to intensify, and, by the spring and summer of 1999, she experienced urinary frequency every 30 minutes to one and one-half hours; nocturia from four to five times per night; urge incontinence requiring the use of several sanitary pads per day; constant pelvic pain; and severe limitations of all activities, including work and recreation. 21. That Dr. Erikson continued to treat Gail Szoboszlay with multiple medications, including Ditropan, Belladonna and opium suppositories, Baclofen, Levsin, and Klonopin, in the hope of containing this young woman's severe bladder difficulties. 22. That in August 1999, Gail Szoboszlay saw in consultation Dr. Joseph Harryhill at the Pennsylvania Hospital, in Philadelphia, who recommended a hydrodistension procedure to take place under general anesthesia to assess the effects of the bladder injury which had occurred at abdominal hysterectomy, and to assess the possibility of the disease process known as interstitial cystitis. 23. That on November 9, 1999, Gail Szoboszlay underwent hydrodistension under general anesthesia performed by Dr. Erikson, who noted signs consistent with the diagnosis of interstitial cystitis, and, additionally, noted intra-operatively multiple fibrous bands of scar tissue connecting the base of the bladder to the posterior bladder wall, which bands were impairing the bladder 5 expansion by tethering it; during the surgical procedure, Dr. Erikson incised the fibrous bands, allowing further expansion of the bladder. 24. That as a consequence of the symptoms and signs consistent with interstitial cystitis which were noted on the hydrodistension procedure of November 9, 1999, Dr. Erikson began Gail Szoboszlay on a treatment regimen of Heparin and Lidocaine installations, as well as continuing her medical regimen of Klonopin, Baclofen, Oxycontin, Elmiron, Elavil, Urocit/K Neurontin, Belladonna and Opium suppositories, Vicodin, and Ditropan; presently, Gail Szoboszlay's medications alone total over $1,800.00 per month cost. 25. That at present, Gail Szoboszlay remains entirely unable to work in any capacity, limited in all activities by severe pain, urinary frequency, nocturia, urge incontinence and the need to catheterize herself eight to ten times daily. 26. That Dr. Erikson has urged Gail Szoboszlay to seek psychological counseling to help her deal with the depression which has developed over the dramatic lifestyle alteration caused by her unabated bladder problems which issued as a result of the abdominal hysterectomy procedure in November of 1998. Ii li II 6 COUNT I Gail Szoboszlay V. George Jeffries, III, M D (Informed Consent) 27. Paragraphs 1 through 26 above are incorporated herein by reference. 28. That the Defendant, Dr. Jeffries, committed a battery in his treatment of Plaintiff when he: a. failed to inform Plaintiff that she could suffer the complication of bladder laceration (otherwise known as inadvertent cystotomy)which could cause her to experience severe and permanent bladder disabilities. 29. That as a result of Dr. Jeffries' conduct as described in the preceding paragraph of this Complaint, Plaintiff, Gail Szoboszlay, was exposed to the risk of bladder injury which complication did, in fact, occur. 30. That as a result of Dr. Jeffries' conduct as described in paragraph 28 above, Plaintiff, through development of the bladder laceration described above, and subsequent complications, encountered an increased risk of developing profound and intractable bladder problems, including, but not limited to 7 --i-] "interstitial cystitis," which conditions are, in fact, still under diagnostic consideration and treatment. 31. That as a result of Dr. Jeffries' conduct as described in paragraph 28 above, Plaintiff has required prolonged and expensive treatment of her bladder disability, including an additional surgery, and will require extensive further treatment in the future. 32. That as a result of Dr. Jeffries' conduct as described in paragraph 28 above, Plaintiff has incurred additional medical expense, and is expected to incur substantial additional medical expense in the future. 33. That as a result of Dr. Jeffries' conduct as described in paragraph 28 above, Plaintiff has suffered a diminution in her earning potential. 34. That as a result of Dr. Jeffries' conduct as described in paragraph 28 above, Plaintiff has been caused to sustain, and will, in the future, continue to sustain pain, suffering, inconvenience, emotional distress, embarrassment, disfigurement, and loss of life's pleasures. WHEREFORE, the Plaintiff, Gail S zoboszlay, demands judgment against George Jeffries, III, M.D. for judgment in excess of $25,000.00, together with interest and costs of suit. 8 I? COUNT II I Gail Szoboszlay V. George Jeffries. III, M.D. ?•" (Negligence) 35. Paragraphs 1 through 39 above are incorporated herein by reference. 36. That the Defendant, Dr. Jeffries, was negligent and careless in the medical treatment and/or advice provided to Plaintiff in that he: a. negligently performed an inadvertent cystotomy during the procedure of abdominal hysterectomy which was conducted on November 17, 1998. 37. That as a result of Dr. Jeffries' conduct as described in the preceding paragraph of this Complaint, Plaintiff, Gail Szoboszlay, was exposed to the risk of bladder injury which complication did, in fact, occur. 38. That as a result of Dr. Jeffries' conduct as described in paragraph 36 above, Plaintiff, through development of the bladder laceration described above, and subsequent complications, encountered an increased risk of developing profound and intractable bladder problems, including, but not limited to 9 i "interstitial cystitis," which conditions are, in fact, still under diagnostic consideration and treatment. 39. That as a result of Dr. Jeffries' conduct as described in paragraph 36 above, Plaintiff has required prolonged and expensive treatment of her bladder disability, including an additional surgery, and will require extensive further treatment in the future. 40. That as a result of Dr. Jeffries' conduct as described in paragraph 36 above, Plaintiff has incurred additional medical expense, and is expected to incur substantial additional medical expense in the future. 41. That as a result of Dr. Jeffries' conduct as described in paragraph 36 above, Plaintiff has suffered a diminution in her earning potential. 42. That as a result of Dr. Jeffries' conduct as described in paragraph 36 above, Plaintiff has been caused to sustain, and will, in the future, continue to sustain pain, suffering, inconvenience, emotional distress, embarrassment, disfigurement, and loss of life's pleasures. WHEREFORE, the Plaintiff, Gail Szoboszlay, demands judgment against George Jeffries, III, M.D. for judgment in excess of $25,000.00, together with interest and costs of suit. 10 V- COUNT III Gail Szoboszlay V. Central Penns lvania Obstetric necolo Inc. (Negligence) 43. Paragraphs 1 through 42 above are incorporated herein by reference. 44. That at all times material hereto, Dr. Jeffries was an v agent, servant and/or employee of the business entity known as within the `e Central Pennsylvania Obstetric/Gynecology, Inc., acting course and scope of that agency and/or employment. c., Defendant, Central Pennsylvania 45. That , Obstetric/ Gynecology, Inc. acted negligently with respect to the l treatment of Gail Szoboszlay as set forth in paragraph 44 above. h WHEREFORE, the Plaintiff, Gail Szoboszlay, demands judgment j ? ` against Central Pennsylvania Obstetric/Gynecology, Inc. for judgment in excess of $25,000.00, together with interest and costs of suit. 11 V COUNT IV Michael Szoboszlay V. George Jeffries, III, M.D. and Central Pennsylvania Obstetric/Gynecoloov. Inc._ (Loss of consortium) 46. Paragraphs 1 through 45 above are incorporated herein by reference. 47. That as a result of the Defendants' negligent conduct as described in the preceding paragraph, Husband Plaintiff, Michael Szoboszlay, has sustained damages as a result of the loss of services, guidance, companionship, society, affection and consortium of his wife. WHEREFORE, Michael Szoboszlay demands judgment against the Defendants for a sum in excess of $25,000.00 together with interest and costs of suit. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. 1! 1 1 BY: wL ?' Ap ' 1 L. Str fitJ-Kutay, Es ID#: 467 8 P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Plaintiffs Date 38354.1 3.2 l I, GAIL SZOBOSZLAY, hereby acknowledge that I am a Plaintiff in this action; that I have read the foregoing document; and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C. S. Section 4904, relating to unswo rn falsification to authorities. .l rN I-, /VI GAIL SZOBOS Y DATE: aI51?o? VERIFICATION I, MICHAEL SZOBOSZLAY, hereby acknowledge that I am a Plaintiff in this action; that I have read the foregoing document; and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C. S. Section 9909, relating to unsworn falsification to authorities. DATE: 4-5-/1Z 000 e I CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person (s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Peter J. Curry, Esquire Thomas, Thomas & Hafer PO Box 999 Harrisburg, PA 17 101 Attorney for Defendants GOLDBERG, KATZMAN & SHIPMAN, P.C. BY: jo? kl= - Aril. St ig-Kutay, Esquire Attorn y fo Plaintiffs Date: B 8 aoao 13 THOMAS, THOMAS & HAFER, LLP By: Peter J. Curry, Esquire Identification No. 16622 305 North Front Street P. O. Box 999 Harrisburg, PA 17108 (717) 255-7637 Attorney for Defendants GAIL SZOBOSZLAY and : IN THE COURT OF COMMON PLEAS OF MICHAEL SZOBOSZLAY, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs Docket No. 99.7637 Civil Term V. GEORGE JEFFRIES, III, M.D., and CENTRAL PENNSYLVANIA : CIVIL ACTION -LAW OBSTETRICS/GYNECOLOGY, INC., Defendants : JURY TRIAL DEMANDED ANSWER OF DEFENDANTS TO PLAINTIFFS' COMPLAINT AND NOW come the Defendants George Jeffries, III, M.D., and Central Pennsylvania Obstetrics/Gynecology, Inc., through their attorneys, Thomas, Thomas & Hafer, LLP, to respond to Plaintiffs' Complaint as follows: 14. The averments contained in Paragraphs 1 through 4 of Plaintiffs' Complaint are admitted. 5: 11. The averments contained in Paragraphs 5 through I 1 of Plaintiffs' Complaint are denied generally in accordance with and pursuant to Pa. R.C.P. 1029(e). 12.-26. The responding Defendants are without sufficient knowledge or information to either admit or deny the averments contained in Paragraphs 12 through 26 of Plaintiffs' Complaint. Pursuant to the Pennsylvania Rules of Civil Procedure, said averments are, therefore, denied, and proof thereof is demanded at the time of trial. COUNTI Gail Szoboszlay v. George Jeffries, III, M.D. (Informed Consent) 27. Paragraphs 1 through 26 of this Answer to Plaintiffs' Complaint are incorporated herein by reference as if set forth at length. 28. The averments contained in Paragraph 28 of Plaintiffs' Complaint set forth conclusions as opposed to statements of fact and no response is required. Nevertheless, said averments are specifically denied and proof thereof is demanded at the time of trial. By way of further response to the averments contained in Paragraph 28, the responding Defendants believe and, therefore, aver that Dr. Jeffries provided Mrs. Szoboszlay with that information which a reasonable person would expect to receive under the same or similar circumstances. 29.-34. The averments contained in Paragraphs 29 through 34 of Plaintiffs' Complaint set forth conclusions as opposed to statements of fact and no response is required. Nevertheless, said averments are denied and proof thereof is demanded at the time of trial. WHEREFORE, responding Defendants demand judgment in their favor and against the Plaintiffs. 1) COUNT 11 Gail Szoboszlay V. George Jeffries, III, M.D. (Negligence) 35. Paragraphs 1 through 34 of this Answer to Plaintiffs' Complaint are incorporated herein by reference as if set forth at length. 36. The averments contained in Paragraph 36 of Plaintiffs' Complaint set forth conclusions as opposed to statements of fact and no response is required. Nevertheless, said averments are specifically denied and proof thereof is demanded at the time of trial. By way of further response to the averments contained in Paragraph 36, the responding Defendants believe and, therefore, aver that at all times relevant hereto, Dr. Jeffries acted in accordance with the required standards of medical care. 37.42. The averments contained in Paragraphs 37 through 42 of Plaintiffs' Complaint set forth conclusions as opposed to statements of fact and no response is required. Nevertheless, said averments are denied and proof thereof is demanded at the time of trial. WHEREFORE, the responding Defendants demand judgment in their favor and against the Plaintiffs. 3 COUNT III Gail Szoboszlay V. Central Pennsylvania Obstetrics/Gynecology, Inc. (Negligence) 43. Paragraphs 1 through 42 of this Answer to Plaintiffs' Complaint are incorporated herein by reference as if set forth at length. 44. The averments contained in Paragraph 44 of Plaintiffs' Complaint are admitted, 45. The averments contained in Paragraph 45 of Plaintiffs' Complaint set forth conclusions as opposed to statements of fact and no response is required. Nevertheless, said averments are specifically denied and proof thereof is demanded at the time of trial. By way of further response to the averments contained in Paragraph 45 of Plaintiffs' Complaint, Paragraph 36 of this Answer to Plaintiffs' Complaint is incorporated herein by reference as if set forth at length. WHEREFORE, the responding Defendants demand judgment in their favor and against the Plaintiffs, COUNT IV Michael Szoboszlay V. George Jeffries, III, M.D., and Central Pennsylvania Obstetrics/Gynecology, Inc. (Loss of Consortium) 46. Paragraphs 1 through 45 of this Answer to Plaintiffs' Complaint are incorporated herein by reference as if set forth at length. srx? 4 47. The averments contained in Paragraph 47 of Plaintiffs' Complaint set forth conclusions as opposed to statements of fact and no response is required. Nevertheless, said averments are denied and proof thereof is demanded at the time of trial. WHEREFORE, the responding Defendants demand judgment in their favor and against the Plaintiffs. 5 Respectfully submitted, VERIFICATION I, George Jeffries, 111, M.D., hereby swear and affirm that the facts and matters set forth in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements made herein are made subject to the penalties of Pa. C.S. §4904 relating to unswom falsification to authorities. Date: 2,119lo6 eorge 'ffri? :72412.1 CERTIFICATE OF SERVICE I, Kathy L. Sitler, an employee of the law offices of Thomas, Thomas & Hafer, LLP, do hereby certify that 1 served the foregoing document upon counsel of record by sending same via United States mail, first class, postage prepaid, as follows: April L. Strang-Kutay, Esquire GOLDBERG, KATZMAN & 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 SHIPMAN, P.C. Date: -?c I ?/1 r.uc?,2 JC_? C? KATHY SITLER GAIL SZOBOSZLAY AND MICHAEL SZOBOSZLAY, HER HUSBAND Plaintiffs VS. GEORGE JEFFRIES, III, M.D. & CENTRAL PENNSYLVANIA OBSTETRICS/GYNECOLOGY, INC. Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW No. 99-7637 JURY TRIAL DEMANDED PRAECIPE TO WITHDRAW APPEARANCE AND ENTRY OF APPEARANCE To The Prothonotary: Please note the withdrawal of appearance of the undersigned. Date: lI 27 vv Please note the entry of appearance of the GOLDBERG, KATZMAN & SHIPMAN, P.C. By: 41X'-'t April . Strang-Kutay, Esquir Attorney I.D. /146728 P O Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 A Date: 14LIVIdO By: Plaintiffs. & BROOTART` L.L.P. William A. Atlee, Jr., Esquire Attorney for Plaintiff 8 North Queen Street P.O. Box 449 Lancaster, PA 17608-0449 (717) 393-9596 Sup. Ct. I.D. No. 06919 11900.1 SM P1=dings%Pm"i02.kmn r Q1 ii C7 ng C I l ?.. C ;X) , u_ O r- GAIL SZOBOSZLAY AND MICHAEL : IN THE COURT OF COMMON PLEAS SZOBOSZLAY, HER HUSBAND : CUMBERLAND COUNTY, PA Plaintiffs : CIVIL ACTION -LAW Vs. No. 99-7637 GEORGE JEFFRIES, III, M.D. & CENTRAL PENNSYLVANIA OBSTETRICS/GYNECOLOGY, INC. :JURY TRIAL DEMANDED Defendants PRAECIPE TO WITHDRAW APPEARANCE To The Prothonotary: Please note the withdrawal of appearance of the undersigned in the above captioned matter. Date: 4I b l o / AT,W,YALL & BvAOKHART,`L.L.P William A. Atlee, Jr., Esquire Attorney for Plaintiffs 8 North Queen Street P.O. Box 449 Lancaster, PA 17608-0449 (717) 393-9596 Sup. Ct. I.D. No. 06919 11:\00.1881Coun\Pmc\Pm ai03.kan1 _ 1 zcg,svz I u 1 2001 D BY: e , CERTIFICATE OF SERVICE I hereby certify that I have this day caused a true and correct copy of the foregoing document, to be served upon the following persons by placing a copy of the said document in the United States mails, first class mail, directed to their office addresses as follows: Peter J. Curry, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street P O Box 999 Harrisburg, Pik 17108 Attorneys for George Jefferies, III, M.D. & Central Pennsylvania Obstetrics/Gynecology, Inc. ?-- Dated yl ?b?DI AEE, H#L & BRC?KHART, L.L.P. By: William A. Atlee, Jr., Esquire / Attorney for Plaintiff 8 North Queen Street P.O. Box 449 Lancaster, PA 17608-0449 (717) 393-9596 Sup. Ct. I. D. No. 06919 _ ..,,-? ,, .. GAIL SZOBOSZLAY and MICHAEL SZOBOSZLAY, her husband, Plaintiffs vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GEORGE JEFFRIES, III, M.D., and NO. 99-7637 Civil Term CENTRAL PENNSYLVANIA OBSTETRICS/GYNECOLOGY, INC., JURY TRIAL DEMANDED Defendants PRAECIPF FOR FNTRY OF APPE611AN r To The Prothonotary: Please note the Entry of Appearance of the undersigned on behalf of the Plaintiffs in the above-captioned matter. Respectfully submitted: Dated: Anvil IL 2001 Da ' J. Foster, Esquire I.D. No. 23151 COSTOPOULOS, FOSTER & FIELDS 831 Market Street/P.O. Box 222 Lemoyne, PA 17043-0222 Phone: (717) 761-2121 Catherine M. Mal ady- mitl sq re I.D. No.: 472452 3115 A North Front Street Harrisburg, PA 17110 Phone: (717) 236-6012 s CERTIFICATE OF SERVICE I, Ami L. Gelbaugh, a paralegal for the law offices of Costopoulos, Foster & Fields, hereby certify that on this I I"day of April, 2001, a true and certified copy of the foregoing Praecipe to Enter Appearance on behalf of the Plaintiffs, was sent via United States mail, first- class, postage prepaid, from Lemoyne, Pennsylvania, addressed as follows: Peter J. Curry, Esquire THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 Craig A. Stone, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 William A. Atlee, Jr., Esquire ATLEE HALL & BROOKHART, LLP 8 North Queen Street P.O. Box 449 Lancaster, PA 17608-0449 L -ej?zj Ami L. Gelbaugh, P legal F-77 ;; . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE NATTER OF: GAIL SZOBOSZLAY _VS_ GEORGE JEFFRIES, III, ND., ET AL COURT OF COKMON PLEAS TERM, CASE NO: 99-7637 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of PETER J. CURRY, ESQ. _ certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. CS o ?jf of ".f DATE: 07/17/2002 PET• J. URRY, :ES Q. Attorney for DEFENDANT DE12-220180 00873--L.01 71755.'6758 cvn.. . PCIIALD SMITH :002.0^-le 10.00 4: i >0 1601 Mnrk" Strom. So" 800. PhOrdclphla Pcnmsyivaaia 19103 (21S) 246.0900 FAX Nambw (215) 246 . W9 URGENT11111 J-3.Y 19. 2002 PAGE ., p1?9 P. 02.'03 UIRG1ENT11111 URGENT11111 CAM SZOaMZW TA NUM GAIL SZAMnM Ve tiUM JPJMM. W. M., Er AL UIM, 'l7 AU. LIT AL PM J. OW, SSG. - (717) 237.7105 We have barn rgaetd by the &ban- mUcead oaalwl to EiRA-fn =tEfW m An aogoditad bins from the below lircad cwtm t1-m. Zn order to =ply with this request we mat tow yea: sipatum 6dlratiny &At ya waive the o.wty-day notice period provided in ]bin 4009.21 and 4009.72. Please fu thin form to us Icws dUt jV at (215) 746-069 with vale nixabsre v that v eay asply with whir raquavt. You cooperation would be 8.mUy ap rec4atmi. SinconLy. Show PR= IMO= 6111 H F W CL =C - KMCAL AIUplAW WYM?SP G,?!(C - MIM OAI Rf0U116 1?w/'( VL JOl9'1'H HA170hm]. . JJWX . wmam PBYSRSlt6 HAaIMIFU - MWMAL 7UD= I'D osmaal= / SAL4 rwMEX0ac tw1A)x-soon. rev ( 1 I AFM co %siw waithny tat z? ?Ocpimr Yee Ib ?C..? I do not agree to waive rule+ RRVI-236612 008 71•-C01 PENNSYLVAN=A C0k4b40NWEA1-TH OE7 CUMBERLAND COUNTY 0V IN THE MATTER OF: COURT OF COMMON PLEAS GAIL S20BOSZLAY -VS- GEORGE JEFFRIES, III, MD., ET AL TERM, CASE NO: 99-7637 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ANN MARIE MANNING, M.D. MEDICAL RECORDS PAIN MANAGEMENT CLINIC MEDICAL RECORDS DR. JOSEPH HARRYBILL MEDICAL RECORDS KEYSTONE UROLOGY,PC MEDICAL RECORDS TO: APRIL L. STANG-RUTAY ESQ HCS on behalf of PETER J- CURRY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to HCS or by contacting our local HCS office. DATE: 07/17/2002 CC: PETER J. CURRY, ESQ. - 430-00019 MICHAEL BOND - Any questions regarding this matter, contact HCS on behalf of PETER J. CURRY, ESQ. Attorney for DEFENDANT THE HCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-193714 C O 8 7 1- 0 0 2 i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY -VS- File No. 99-7637 GEORGE JEFFRIES, III, M.D., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 T0: CUSTODIAN OF RECORDS FOR: ANN MARIE MANNING, M.D. (Name of pemon or Entity) Wlthln twenty (20) days a1111 service of this subpoena, y°S EEep?det{rCHE6 the court to produce the following documents or t hings: 1T At THE MCS GROUP INC., 1601 MARKET STREET, 11800, PHILADELPHIA PA 19103 (Address) YOU may dellvrr or mall Irglble copies of the documents or produce things requested by this subpoena, together with the eoniflcale of compliance, to Ilia party making this request at the address listed above. You have the right to seek, in Advance, I he reasonable cost o( 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 snhporna may seek a court order compelling you to comply with it. 711 IS SUBPOENA WAS ISSUED AT THE REQUEST OFTHE FOLLOWING PERSON: NAME: PIiTP.R J. CURRY. ESQ. ADDRESSI 305 N. FRONT STREET, P.O. BOX 999 HARRISBURG PA 17108 TFLEPIIONF.: (215) 246-0900 SUPREME COURT ID M: ATTORNEY FOR: THE DEFENDANT BYTH COURT: n /, (f ?, ?J d+ DATE: dc/?of Pmthonoury/Cle CIWI Division , Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ANN MARIE MANNING, M.D. 473 NORTH 21ST STREGr CAMP HILL, PA 17011 RE: 871 GAIL, SZOBOSZLAY FNA MILLER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consuitation, care or treatment. Dates Requested: up to and including the present. Subject : GAIL SZOBOSZLAY FNA MILLER 142 FOREST DR., CAMP FMJ, PA 17011 Social Security A 186-60-8490 Date of Birth: 07-12-1970 SU10-386002 008731-L01 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IH THE FLATTER OF: GAIL SZOBOSZLAY _VS_ GEORGE JEFFRIES, III. MD., ET AL COURT OF COPMON PLEAS TERM. CASE NO: 99-7637 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of PETER J CURRY ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and. (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 0711712002 PETER J CURRY ESQ. Attorney for DEFENDANT NI A DE12-220181 0 0 8 7 1- 1,0 2 C 0Mt4O NWEAL T H C )F- PENNSYLVANIA COUNTY OF' CUMBERLAND IN THE HATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY -VS- GEORGE JEFFRIES, III, MD., ET AL ANN MARIE MANNING, M.D. MEDICAL RECORDS PAIN MANAGEMENT CLINIC MEDICAL RECORDS DR. JOSEPH HARRYBILL MEDICAL RECORDS KEYSTONE UROLOGY,PC MEDICAL RECORDS TO: APRIL L. STANG-KUTAY ESQ TERM, CASE NO: 99-7637 MCS on behalf of PETER J. CURRY, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local HCS office. DATE: 07/17/2002 CC: PETER J. CURRY, ESQ. - 430-00019 MICHAEL BOND - Any questions regarding this matter, contact MCS on behalf of PETER J. CURRY, ESQ. Attorney for DEFENDANT THE NCS GROUP INC. 1601 MARKET STREET /800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-193714 00877.-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY -VS- GEORGE JEFFRIES, III, M.D., ET AL File No. og-76i7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PAIN MANAGEMENT CLINIC (Name of Penon ar Entim Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: at :Pzig NCR rRQTTP 'TUC-1.6111-MARKET STREET 2800. PHILADELPHIA PA 19103 (Addmq 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 corn pelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PETER J. CURRY ADDRESS: 305 N. FRONT ST., P.O. BOX 999 HARRISBURG PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID k: ATTORNEY FOR: THE DEFENDANT BY E COURTs DATE: h ? Prothonotary/0 p CIv Division Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PAIN MANAGIiMENI'CIdNIC 5 SPRINT DRIVE CARLISLE, PA 17013 RE: 671 GAILSZOBOSZLAY FNA MILLER INCLUDING ANY AND ALL RECORDS FROM TED KOSENSKE, MD Any and all records, correspondence, riles and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : GAIL SZOROSZLAY FNA M J ER 142 FOREST DR., CAMP HILL, PA 17011 Soda] SecurityA 186-60-8490 Date of Birth: 07-12-1970 SU10-386004 00871-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GAIL S20BOSZLAY TERM, _VS_ CASE NO: 99-7637 GEORGE JEFFRIES, III, MD., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of PETER J. CURRY, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 0711712002 PETER J. CURRY, ESQ. Attorney for DEFENDANT DE12-220182 00873--1,03 l) ?.I COKMONWEAI.,TH OF' PENNSYL.VAN=A COUNTY OE' CTJk4BEE2S.AND IN THE HATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY -VS- GEORGE JEFFRIES, III, MD., ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO THINGS FOR DISCOVERY PURSUANT T ANN MARIE MANNING, H.D. MEDICAL RECORDS PAIN MANAGEMENT CLINIC MEDICAL RECORDS DR. JOSEPH HARRYHILL MEDICAL RECORDS KEYSTONE D'ROLOGY,PC MEDICAL RECORDS TO: APRIL L. STANG-KUTAY ESQ TERM, CASE NO: 99-7637 MCS on behalf of PETER J. CURRY. ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office- DATE: 07/17/2002 CC: PETER J. CURRY, ESQ. - 430-00019 MICHAEL BOND _ MCS on behalf of -PETER J. CURRY. ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-193714 0 0 8 7 1- C O 2 i rt _Xrlt COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY -VS- GEORGE JEFFRIES, III, M.D., ET AL File No. qq-7697 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:CIISTODIAN OF RECORDS FOR: DR. JOSEPH HARRYHILL (Name of Pena. or Entity) Within twenty (20) days after service of this subpoena, ou are ordered by the court to produce the following documents or things SYEE ATTACHED at THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA PA 19103 (Addms( You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after Its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:PETER J. CURRY. ES ADDRESSo305 N. FRONT STREET P.O. BOX 999 HARRISBURG PA 17108 TELEPHONE: (2I 51 946-ngnn SUPREMECOURTIDk: ATTORNEYFOR: THE DEFENDANT n B? COURT„r?J DATE: 41..Ot _ ? ? L hoon?mary „vll Ivlslon Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JOSEPH 11ARRYIIILL 2999 S. 9111 STRELT PHILA, PA 19106 RE: 871 GAIL SZOBOSZLAY ITIA MILLER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : GAIL SZOBOSZLAY FNA MILLER 142 FOREST DR., CAMP HILL, PA 17011 Social Security A 186.60-8490 Date of Birth: 07-12-1970 SU10-386006 00871-1,03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF, GAIL SZOBOSZLAY _VS_ GEORGE JEFFR.IES, III, MD., ET AL COURT OF COMMON PLEAS TERM. CASE NO: 99-7637 As a prerequisite to service of a subpoena for document s and things pursuant to Rule 4009.22 MCS on behalf of PETER J CURRY ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identic a 1 to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 0711712002 PETER J CURRY ESQ. Attorney for DEFENDANT DE12-220183 00871-L04 w?wb® CObIMONWEATI 17H OF PENNSYL,VA?N2A COUNTY OF CIJMBERT•AND IN THE NATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY -VS- TERM, CASE NO: 99_7637 GEORGE JEFFRIES, III, MD., ET AL ANN MARIE PLANNING, M.D. MEDICAL RECORDS PAIN MANAGEMENT CLINIC MEDICAL RECORDS DR. JOSEPH HARRYHILL MEDICAL RECORDS KEYSTONE UROLOGY, PC MEDICAL RECORDS TO: APRIL L. STANG-KUTAY ESQ MCS on behalf of PETER J. CIIRRY ESQ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your erpense by completing the attached counsel card and returning same to MCS or by contacting our local HCS office- DATE: 07/17/2002 HCS on behalf of ld - -PETER J. CURRY ESQ Attorney for DEFENDANT CC: PETER J_ CURRY, ESQ. - 430-00019 MICHAEL BOND _ Any questions regarding this matter, contact THE HCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-193714 0 0 8 7 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOEOSZLAY -VS- GEORGE JEFFRIES, III, M.D., ET AL File No. qq-7637 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: KEYSTONE UROLOGY, PC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SF.F. ATTACHED at THE MCS GROUP INC., 1601 MARKET STREET, 11800, PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after Its service, the parry serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PETER J. CURRY, ESQ. ADDRESS:305 N. FRONT STREET, P.O. BOX 999 HARRISBURG PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID k: ATTORNEY FOR: THE DEFENDANT BY Tfg COURT: DATE: Prothonoott?;ry!f/ r Civil vision (/ aLa /??/ du d Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUS'T'ODIAN OF RECORDS FOR: KEYSTONE UROLOGY,PC 645 IZI7I S'fRtili'1' S'IT. 300 LEMOYNE, PA 17043 RE: 871 GAIL SZOBOSZLAY I14A MILLER INCLUDING ANY AND ALL RECORDS FROM DR. PAUL II. SMITH Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: from: 03-23-1999 to the present. Subject : GAIL SZOBOSZLAY ENA MILLER 142 FOREST DR, CAMP HILL, PA 17011 Social Security N: 186-60-8490 Date of Birth: 07-12-1970 SUIO-386008 00871-1L.04 /? 4.? 4 ` r L) ?? _ ...?C_ '. ? ?.? ?_?! i; - i ?1 =;) ?., _. U . ^?? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY TERM, -VS- CASE NO: 99-7637 GEORGE JEFFRIES, III, MD., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P. O'NEILL, III, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS n o5 DATE: 04/1412003 GH P. 0'NE L, III, ESQ. Attorney for DEFENDANT DE12-223910 00873--1,05 MC5 1601 Market Street, Suite 800, Philadelphia Pennsylvania 19103 (215) 246 - 0900 Fax Number (215) 246 - 0959 URGENTMH URGENT M! URGENT!!!!! APRIL 14, 2003 GAIL SZOWS27AY FNA hIILLFR GAIL SZOBOSZLAY Vs GEORGE JEFFRIES, III, M., Er AL 7HONFS, TW, S, Er AL HM P. 0-NMT , III, ESQ. - (717) 237-7105 We have been requested by the above-mentioned oamsel to obtain material on an expedited basis from the below listed custodians. In order to caTply with this request we must have your sigroture indicating that you waive the twenty-day notice period provided in Rules 4009.21 and 4009.22. Please fax this form to us immediately at (215) 246-0959 with your signature so that we msy crnply with this request. Your cooperation would be greatly appreciated. Sincerely, SAKIW PRICE Custodians: FIILMN S. HERSHEY MMICAL CIR. - 6'®=CAL RECI7RAS DEBORAH ERIKS N, MD - MEDXCAL RFIOMS Damsel: CA1HOME MVLW-SA417H, M. /?(717) 23y-68 3 I agree to waive waiting period???k VG( Da[e: L ?oF?S Copies: Yes_ No I agree to pay the invoice provided with the doc mats I do not agree to waive rule: Irate: CRAIG S10NE, ESQ. (717) 236-1816 I agree to waive waiting period Date: Copies: Yes_ No I agree to pay the invoice provicbd with the doarrents I do not agree to waive rile: Date: RRW1-13 9045 0 0 8 7 r'P3-14-2003 HON 0203 PM FAR N0. .? -. P. 02/02 0dilarace3 t1:15 k -- t10. 4'J4 Dael n A I 1601hfarketStreet, Suitt 800, PhiladelphiaPeaasylvaaia 19103 I t _ (215) 246.11900 Pa:t Number (215) 246.0959 I? URGENTIIII.' URGENTIM! URGENTIIIII APRIL 1:, 1003 Gas, Sa0BOSW trm N.IIM l .dII, =41r>SZt71Y Vs t JFFMS, III, Ia., ET AL s19DW' tins, -;x AL KM P. O'la=, =, M - (717) 237-7105 Ae have bem regJested ty the above-tnmtiawdl coursd to obtain material crw an expedited basis Fran tie below 34uted gi9toch=. In octhr to catply With this regaeat wR n= lave W= sign 'At! ind a&UM 04 you waive tt4 twenty-di/ notice period ptoAti:d !n P11eS 4009.21 and 4009.22. Please fax this, foam to us iimeatttely at (215) 246-0959 with Y-= Si ratin 0 that we may o3vly with this request, Your cooperation wrnld be greatly a<ppre x7 Siroerely, Cltsta UAW: UZ'IW S. M SW FfMOL CIR. - MMICAL =MS WOW ?R!] OV, M) - 14MCAL RBX5CS oamsel: C1411t11M U44FM-S419A, ISO. (717) 236.6823 I agree to waive waiting perial rite: Cbpies: Yes Io I agree to pay the irvice parrited with the doavent; I da not agree to waive rule: Date: MIG SMMI FM. 7 I agree to wuivtt wai till petits hate: A.L?-1 1 o (tpie.7: Yes -_:W--- L at to {ay t invoice prv ickd with the d=m-its r 00 rM agree to waive Vila, ,Y pate: MI-139045 0 0 13 71 -CO 3_ C O M M ONW EAL1rH Or P E NN S Y LVAN 2 A COUNTY OF CUMBER LAND IN THE MATTER OP: _ COURT OF COMMON PLEAS GAIL SZOBOSZLAY -VS- GEORGE JEPPRIES, III, MD., ET AL MILTON S. HERSHEY MEDICAL CTR. MEDICAL RECORDS DEBORAH ERIKSON, MD MEDICAL RECORDS TERM, CASE NO: 99-7637 TO: CRAIG STONE, ESQ. CATHERINE MAHADY-SMITH, ESQ. MCS on behalf of HUGH P. O'NEILL, III, ESQ. intends to serve a subpoena , identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/14/2003 CC: HUGH P. O'NEILL, III, ESQ. - 430-00019 MICHAEL BOND - 430-00019 MCS on behalf of HUGH P. O'NEILL, III, ESQ. Attorney for DEPENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-223085 0 0 87 1- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY' -VS- FileNo. 99-7637 GEORGE JEFFRIES, III, M.D., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty 120) days after service of this subpoena, You are ordered by the court to produce the following documents or things: SEE ATTACHED at THE MCS GROUP, INC., 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME. HUGH P. O'NEILL, III, ESQUIRE ADDRESS: 305 NORTH FRONT STREET, PO BOX 999 HARRISBURG PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEYFOR: DEFENDANT n APR 2 5 2003 BYT COURT: DATE: ianeLj L ) Prarhonolan•1Cl.r Civil !on L ?6 D¢pu e Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL CTR. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 871 GAIL SZOBOSZLAY FNA MILLER ALL RECORDS FOR THIS PATIENT UNDER BOTH NAMES. Entire ho ual medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, tests, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: GAIL SZOBOSZLAY FNA MILLER 142 FOREST DR., CAMP HILL, PA 17011 Social Security #: 186-60-8490 Date of Birth: 07-12_1970 SUIO-435836 00873.-L 05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: GAIL SZOBOSZLAY -VS- COURT OF COMMON PLEAS TERM, GEORGE JEFFRIES, III, MD., ET AL CASE NO: 99-7637 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P O'NEILL III ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy"of the subpoena attached thereto was mailed or delivered to each party 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) The parties have ave waived thetwenty-day notice provided in and 4009.22 and, Rules ntentstodserveatheosuthe bp enaPoena which the served (4) ise attached subpoena to which MCS on behalf of DATE: 0411412003 HUGH P O'NEILL III ESQ, Attorney for DEFENDANT DE12-223911 00a73--L 06 COMMONWEALTH OP P E NN S Y L VAN 2 A COUNTY O Y C UM B E R L AND COURT OF COMMON PLEAS IN THE MATTER OF: GAIL SZOBOSZLAY -VS- GEORGE JEFFRIES, III, MD., ET AL MILTON S. HERSHEY MEDICAL CTR. MEDICAL RECORDS DEBORAH ERIKSON, MD TERM, CASE NO: 99-7637 TO: CATHERINE MAHADY-SMITH, ESQ. CRAIG STONE, ESQ. MCS on behalf of HUGH P. O'NEILL, III, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/14/2003 CC: HUGH P. O'NBILL, III, ESQ. - - 430-00019 430-00019 MICHAEL BOND Any questions regarding this matter, contact MCS on behalf of HUGH P O'NEILL III, ESQ. Attorney for DBFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-223084 0 0 8 7 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY- -VS- File No. 99-7637 GEORGE JEFFRIES, III, M.D., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DEBORAH ERIKSON, M.D. (fame of Pemon or Entity) Within twenty (20) days after service of this subpoenSEa, you are ordered by the court to produce the following documents or things: E ATTACHED at THE MCS GROUP, INC., 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of prepuing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME. HUGH P. O'NEILL, III, ESQUIRE ADDRESS: 305 NORTH FRONT STREET, PO BOX 999 HARRISBURG PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID ti: ATTORNEYFOR: DEFENDANT APR 2 5 2003 DATE: Pp/Ll L. 17 Q-A) Seal of the Court (Eff. 7/97) V."., EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DEBORAH ERIKSON, MD PO BOX 850 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 871 GAIL SZOBOSZLAY FNA MILLER COPY OF 'SHADOW FILE'. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: ent. Dates Requested: up to and incluW= Subject: GAIL S pBOSZLAY F142 FOREST DR., CAMP MILL, PA 17011 Social Security /!: 18640-8490 Date of Birth: 07-12-1970 SU10-435838 00871-L 06 Y Ct> ?? ? ? °) u . - ? i? !' = _. _ ? i :h '..? i; ._ 1 i? ??_ >' ? U LL [?! ^? U" o U CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY TERM, -VS- CASE NO: 99-7637 GEORGE JEFFRIES, III, MD., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P. O'NEILL, III, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07%14/2003 HttH H O'NEILL, III, ESQ Attorney for DEFENDANT DE11-434787 0 0 8 7 1 -1,0 7 COMMONWEALTH OF P E N N S Y L VAN 2 A COUNTY or C UM S M R L AND IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY -VS- GEORGE JEFFRIES, III, MD., ET AL TO MINNESOTA MUTUAL GROUP INS. PA BUREAU OF DISABILITY DETER. FORTIS BENEFITS INSURANCE CO BUCHANAN INGERSOLL KRISTENE WHITMORE, M.D. ERIC ROVNER, M.D. INSURANCE DISABILITY FILE DISABILITY FILE LIABILITY FILE MEDICAL RECORDS MEDICAL RECORDS TERM, CASE NO: 99-7637 AND TO: CATHERINE MAHADY-SMITH, ESQ. CRAIG STONE, ESQ. MCS on behalf of HUGH P. O'NEILL, III, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/24/2003 CC: HUGH P. O'NEILL, III, ESQ. - 430-00019 MICHAEL BOND - 430-00019 Any questions regarding this matter, contact MCS on behalf of HUGH P. O'NEILL, III, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 0800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-231761 0 087 1-C02 J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY VS GEORGE JEFFRIES,III, MD ., ET AL File No. 99-7637 SUBPOETNATO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ML 90TA MUTII L GROUP TNS_ (Name of Person or Entity) Within twenty (20) days after service- of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC 1 601 MARKET ST 1800 PNTTA PA 19104 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME. HUGH P. O'NEILL, III, ESQ. ADDRESS: 305 NORTH FRONT ST., PO B% 999 HARRISBURG, PA_ 17108 TELEPHONE: 715-746-no trt0 SUPREME COURT ID k: ATTORNEY FOR: DEFENDANT 2 BY E CURT DATE: .J it Prolhunotary/Cluk, ivision i U mute Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MINNESOTA MUTUAL GROUP INS. P. 0. BOX 64114 ST. PAUL, MN 55164 RE: 871 GAIL SZOBOSZLAY FNA MILLER COMPLETE COPY OF INSURANCE CHART TO INCLUDE SCANS, X-RAYS, PROGRESS NOTES, LABS, & ANY & ALL OTHER RECORDS THAT COMPILE YOUR RECORDS. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiffs claim, payments including dates of payments, payee and reasons for payments, including any and all such items stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : GAIL SZOBOSZLAY FNA MILLER 142 FOREST DR., CAMP HILL, PA 17011 Social Security N: 186-60-8490 Date of Birth: 07-12-1970 SU10-450194 00871-L07 CERTI FICATE PRF,REQUISI7'E TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY TERM, -VS- CASE NO: 99-7637 GEORGE JEFFRIES, III, MD., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P. O'NEILL, III, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent, to serve the subpoena. VCS on behalf of DATE: 07/14/2003 HUGH P. O'NEILL, III, ESQ. Attorney for DEFENDANT DE11-434788 0 0 8 7 1- L O 8 L C O M M O N W E A L T H OP P E N N S Y L VANS A COUNT Y (DF C U M B E R L AN D IN THE MATTER OF: GAIL SZOBOSZLAY VS- GEORGE JEFFRIES, III, MD., ET AL COURT OF COMMON PLEAS TERM, CASE NO: 99-7637 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MINNESOTA MUTUAL GROUP INS. PA BUREAU OF DISABILITY DETER. FORTIS BENEFITS INSURANCE CO BUCHANAN INGERSOLL RRISTENE WHITMORE, M.D. ERIC ROVNER, M.D. INSURANCE DISABILITY FILE DISABILITY FILE LIABILITY FILE MEDICAL RECORDS MEDICAL RECORDS TO: CATHERINE MAHADY-SMITH, ESQ. CRAIG STONE, ESQ. MCS on behalf of HUGH P. O'NEILL, III, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/24/2003 CC: HUGH P. O'NEILL, III, ESQ. - 430-00019 MICHAEL BOND - 430-00019 Any questions regarding this matter, contact MCS on behalf of HUGH P. O'NEILL, III, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 - DE02-231761 0087:L-CO2 r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY VS File No. 99-7637 GEORGE JEFFRIES,III, MD., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: CUSTODTAm nv nnr.nnn. -_ _. __ Within twenty (20) days after service of this things: I.Yame of Person are ordered by the court to produce the following documents or :ACM at 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: NAaIIE: HUGH P. OrHEILL III ES Q, ADDRESS: 305 NORTH FRONT ST., PO B% 999 HARRISBUHO, PA 17108 TELEPHONE: _215-946-nonn SUPREME COURT ID q: ATTORNEY FOR: DEFENDANT DATE: JUL ri 2003 B?-e f . f? a? Prothonotary/Clerk. Division D,u Seal of the Court (Eff. 7/97) J, E"LANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PA BUREAU OF DISABILITY DETER. 1171 S. CAMERON STREET ROOM 200 HARRISBURG, PA 17104 RE: 871 GAIL SZOBOSZLAY FNA MILLER TDNX0038379694, SSNX 186-60-8490 Entire disability file, including but not limited to m records edical reports and/or , claims, any and all correspondence, documentation supporting plaintiffs claim, applications, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: upp to and including the present. Subject : GAIL SZOBOSZLAY FNA MILLER FORFSr Social ? ty # 186 840o AMP FULL, PA 17011 Date of Birth: 07-12-1970 SU10-450196 00871-LOB iii i ' - - - - CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY TERM, -VS- GEORGE JEFFRIES, III, MD., ET AL CASE NO: 99-7637 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P. O'NEILL, III, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/14/2003 HUGH P. O'NEILL, III, ESQ. Attorney for DEFENDANT DE11-434789 00873.-L 09 C O M M O N W E A L T H OF P E N N S Y L VANS A COUNTY OF C UMBER LAN D IN THE MATTER OF: GAIL SZOBOSZLAY VS- GEORGE JEFFRI-c S, III, MD., ET AL SERVE MINNESOTA MUTUAL GROUP INS. PA BUREAU OF DISABILITY DETER. FORTIS BENEFITS INSURANCE CO BUCHANAN INGERSOLL RRISTENE WHITMORE, M.D. ERIC ROVNER, M.D. INSURANCE DISABILITY FILE DISABILITY FILE LIABILITY FILE MEDICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 99-7637 TO: CATHERINE MAHADY-SMITH, ESQ. CRAIG STONE, ESQ. MCS on behalf of HUGH P. O'NEILL, III, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/24/2003 CC: HUGH P. O'NEILL, III, ESQ. - 430-00019 MICHAEL BOND - 430-00019 MCS on behalf of HUGH P. O'NEILL, III ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-231761 0 0 8 '73. -C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY VS GEORGE JEFFRIES,III, HD., ET AL File No. 99-7637 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR, FORTIS BENEFITS INS. CO. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS DROOP INC 1601 NAAFI' ST j8nn ptrTTA PA 191n3 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the parry serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: HUGH P OeNEILL III ESQ. ADDRESS: 305 NORTB FRONT ST., PO B% 999 HARRISBURG, PA 17105 TELEPHONE: 21 s246-ntlnn SUPREME COURT ID B: ATTORNEY FOR: DEFENDANT ;IJL 74'2003 BYgHEC URF1 DATE: /!w t/ J X33 ProthonJoottary/Clerk i Division / -I Putt' Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FORTIS BENEFITS INSURANCE CO PO BOX 419568 KANSAS CITY, MO 641416568 RE: 871 GAIL SZOBOSZLAY FNA MILLER POLICY # 40112964"181, CLAIM# C73227. Entire disability file, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, applications, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: u to and including the present. Subject: 1422 I FFOSREST DRRL..C? MILLER 17011 Social Security #: 18660-8490 Date of Birth: 07-12-1970 SU10-450198 0 0 8 7 1- L O 9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY TERM, -vs- GEORGE JEFFRIES, III, MD., ET AL CASE NO: 99-7637 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P. O'NEILL, III, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the sub ooena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/14/2003 HUGH P. O'NEILL, III, ESQ. Attorney for DEFENDANT DE11-434790 0 0 8 7 1- 1,3-0 COMNIONWEALTH OF PENNSYLVANIA COUNTY OF C U M B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZ090SZLAY -VS - GEORGE JEFFRIES, III, MD., ET AL TERM, CASE NO: 99-7637 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MINNESOTA MUTUAL GROUP INS. PA BUREAU OF DISABILITY DETER. FORTIS BENEFITS INSURANCE CO BUCHANAN INGERSOLL KRISTENE WHITMORE, M.D. ERIC ROVNER, M.D. INSURANCE DISABILITY FILE DISABILITY FILE LIABILITY FILE MEDICAL RECORDS MEDICAL RECORDS TO: CATHERINE MAHADY-SMITH, ESQ. CRAIG STONE, ESQ. MCS on behalf of HUGH P. OINEILL, III, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/24/2003 CC: HUGH P. O'NEILL, III, ESQ. - 430-00019 MICHAEL BOND - 430-00019 Any questions regarding this matter, contact MCS on behalf of HUGH P. O'NEILL, III, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-231761 0 0 8-73.-(--02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOHOSZLAY VS GEORGE JEFFRIES,III, HD., ET AL File No. 99-7637 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE4009.22 TO: Within twenty (20) days after service of this subpc things: Name of Penon ar Entity) you are ordered by the court to produce the following documents or ArrAfnnm at MCS GROUP INC. ]fi,01 (Addresn) 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. TIfIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: HUGH P. OsNEILL III ESO ADDRESS: 305 NORTH FRONT ST., PO RX 999 HARRISBURG, PA 17108 TELEPHONE: 21 9_)L"gn0 SUPREME COURT ID #: ATTORNEYFOR: DEFENDANT JUL i Il 2003 DATE: Z Seal of the Court BY Tyj? //JJ ProthonotanyCCleerrk,, ?C• i ivi,ion D. un• (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BUCHANANINGERSOLL ONE SOUTH MARKET SQUARE 213 MARKET ST. HARRISBURG, PA 17101 RE: 871 GAIL SZOBOSZLAY FNA MILLER CASE N CV-99-2207, GAIL SZOBOSZLAY V. THE LINCOLN NATIONAL LIFE INSURANCE CO. Entire liability file, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such item- as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: GAIL SZOBOSZLAY FNA MILER 142 FOREST DR., CAMP HILL, PA 17011 Social Security #: 186-60-8490 Date of Birth: 07-12-1970 SU10-450200 00871-L10 CERTIFICATE: PREREQUISITE. TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY TERM, -VS- CASE NO: 99-7637 GEORGE JEFFRIES, III, MD., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P. O'NEILL, III, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/14/2003 HUGH P. O'NEILL, III, ESQ. Attorney for DEFENDANT DE11-434791 0 0 8 7 1- L 3- 3. r, C O M M O N W EAL T H OF LP E N N S Y L VANS A COUNTY OF C UM S E R L A ND IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY TERM, -VS- CASE N0; 99-7637 GEORGE JEFFRIES, III, MD., ET AL MINNESOTA MUTUAL GROUP INS. PA BUREAU OF DISABILITY DETER. FORTIS BENEFITS INSURANCE CO BUCHANAN INGERSOLL RRISTENE WHITMORE, M.D. ERIC ROVNER, M.D. INSURANCE DISABILITY FILE DISABILITY FILE LIABILITY FILE MEDICAL RECORDS MEDICAL RECORDS TO: CATHERINE MAHADY-SMITH, ESQ. CRAIG STONE, ESQ. MCS on behalf of HUGH P. O'NEILL, III ESQ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an abjection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/24/2003 MCS on behalf of HUGH P. O'NEILL III ESO Attorney for DEFENDANT CC: HUGH P. O'NEILL MICHAEL BOND III, ESQ. - 430-00019 - 430-00019 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 9800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-231761 0 0 87 1-C0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY VS GEORGE JEFFRIES,III, MD., ET AL File No. 99-7637 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: KRISTENE WBITMORE, M.D. IName of Penonor Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC 1601 MARKET qT OJI PHT a PA 19103 (Addmq You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME. HUGH P. O'NErLL III, ESQ. ADDRESS: 305 NORTH FRONT ST., PO BB 999 HARRISBURG, PA 17108 TELEPHONE: 21 ci246-n90n SUPREME COURT 1D X: .ATTORNEY FOR: DEFENDANT JUI 1 4 2003 BY=j DATE: a063 Prathanatan'/C erk, CM uion Drp n• Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KRISTENE WHITMORE, M.D. 1800 LOMBARDI STREET SUITE 805 PHILADELPHIA, PA 19146 RE: 871 GAIL SZOBOSZLAY FNA MILLER Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians files, memoranda, handwritten notes, history and physical reports , , medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested. up to and including the present. Subject : GAIL SZOBOSZLAY FNA MMLER Social 142 FOREST DR., CAMP HILL, PA 17011 Date of07-118 60-8499 Birth: SU10-450202 00073_-L 3.3. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: GAIL SZOBOSZLAY COURT OF COMMON PLEAS TERM, -VS- CASE N0: 99-7637 GEORGE JEFFRIES, III, MD., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HUGH P. O'NEILL, III, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/=003 HUGH P. O'NEILL, III, ESQ Attorney for DEFENDANT , i DE11-434792 0 087a. -L12 i Comm O N W EA L T H O EP P E N N S Y L VANS A COUNTY OF C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS GAIL SZOBOSZLAY -VS - GEORGE JEFFRIES, III, MD., ET AL MINNESOTA MUTUAL GROUP INS. PA BUREAU OF DISABILITY DETER. FORTIS BENEFITS INSURANCE CO BUCHANAN INGERSOLL, RRISTENE WHITMORE, M.D. ERIC ROVNER, M.D. INSURANCE DISABILITY FILE DISABILITY FILE LIABILITY PILE MEDICAL RECORDS MEDICAL RECORDS TERM, CASE NO: 99-7637 TO: CATHERINE MAHADY-SMITH, ESQ. CRAIG STONE, ESQ. MCS on behalf of HUGH P. O'NEILL, III, ESQ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/24/2003 MCS on behalf of HUGH P. O'NEILL, III, ESQ Attorney for DEPENDANT CC: HUGH P. O'NEILL, III,ESQ. - 430-00019 MICHAEL BOND - 430-00019 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-231761 00B73--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GAIL SZOBOSZLAY VS File No. 99-7637 GEORGE JEFFRIES,III, MD., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: of Person or Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE A A( $Ep at MCS GROUP INC.. 1601 MARKET CT #RD?, PRTi? pA 19101 (Addras) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: HUGH P. O'NEILL III ESQ ADDRESS: 305 NORTH FRONT ST., PO Bg 999 HARRISBURG, PA 17108 TELEPHONE: 71 9-246-no nn SUPREME COURT ID N: ATTORNEY FOR: DEFMANT JUi 1 4 2003 DATE: / ?r P ?(Yi? itl IIIECO RED I; t Proth/o?notary{Clerk. Civil Divisio /- 0 2, Deputy- L Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ERIC ROVNER, M.D. PENN UROLOGY DEPARTMENT 3400 SPRUCE STREETN PHILADELPHIA, PA 19104 IRE: 871 GAIL SZOBOSZLAY FNA MILLER Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: GAIL SZOBOSZLAY FNA MILLER 142 FOREST DR., CAMP EULT , PA 17011 S0c321 Security N: 186-60.8490 Date of Birth: 07-12-1970 SU10-450204 0 08 7 1- 1. 3-2