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HomeMy WebLinkAbout03-3679 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003 ?J(,11 Civil Action - (XX) Law ( ) Equity Civil Veronica L. Davis 601 Cumberland Point Circle Mechanicsburg, PA 170!jO Bonnie Keltz and Lynn Keltz 621 E Winding Hill Rd. Mechanicsburg, PA 17055 versus Plaintiff(sl & Address(es) Defendant(sl & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. Two (2) Writs of Summons Shall be issued and forwarded to ( IAttorney (XX)Sheriff Matthew S. Crosby, Esauire 1300 Linalestown Rd. Harrisbura, PA 17110 (717) 238-2000 Name/Address/Telephone No. of Attorney 69367 Date: l/l.(,/rI}J WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(SI: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. (~~~ ~""O~ :':'c"&::] "'~~" ~::o~ ''''''00'' ,"'m::,," . ~ PROTHON. - 55 W~ '----. . - ~ () ()>, ~ ~ ...... C --.J ~ ~ ~ c....r- <-Nj - "'-\...J r-........ J (y, ,Vi c:-..; "-" V' C" C'l @ (") <:::> 0 c: ~,:; -" ~,.. S= "Uu ~..:J ""r: ;= -p -s:; ~-: (-. W n, ....- ',' '.-:::J C/.) Cl -/' I ~~.~ '- . 0 .~ -'Ii ~i~- -" (~) :.'.) l-n !:-" ~~ -.l SHERIFF'S RETURN - REGULAR CASE NO: 2003-03679 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DAVIS VERONICA L VS KELTZ BONNIE ET AL BRYAN WARD , Sheriff or Deputy Sheriff of says, the within WRIT OF SUMMONS Cumberland County, Pennsylvania, who being duly sworn according to law, KELTZ BONNIE was served upon the DEFENDANT , at 1941:00 HOURS, on the 12th day of August , 2003 at 621E WINDING HILL ROAD MECHANICSBURG, PA 17055 BONNIE KELTZ by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.28 .00 10.00 .00 36.28 Sworn and Subscribed to before me this ;J.1~ day of a'1(I.,r:lb<.>3 A. D . i-l a J'hdj'd IJ;d? ~onotary , So Answers: r~~ R. Thomas Kline 08/13/2003 HANDLER HENNING ROSENBERG ~ s:':;-) By: SHERIFF'S RETURN - REGULAR CASE NO: 2003-03679 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DAVIS VERONICA L VS KELTZ BONNIE ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon KELTZ LYNN the DEFENDANT , at 1941:00 HOURS, on the 12th day of August , 2003 at 621E WINDING HILL ROAD MECHANICSBURG, PA 17055 by handing to BONNIE KELTZ, MOTHER a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r~~~~ .,,- R. Thomas Kline 08/13/2003 HANDLER HENNING ROSENBERG Sworn and Subscribed to before By: ~ ,[;/.,7 J me this .;l7 e< day of Dn1.'UJ :J...vv..3 A. D. n .,. , () 1n.JJJ~ If/'~ ~6thonotary 'i~7 VERONICA L. DAVIS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2003-3679 CIVIL BONNIE KELTZ and LYNN KELTZ, Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of the Defendants, Bonnie Keltz and Lynn Keltz, in the above captioned case. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN ~- BY: phen J. Barcavage, Esquire LD. No. 78867 4200 Crums Mill Road Harrisburg, IP A 17112 (717) 651-3506 Attorneys for the Defendants DATE: VERONICA L. DAVIS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003-3679 CIVIL BONNIE KELTZ and L YNN KELTZ, Defendants CERTIFICATE OF SERVICl~ I, Angela Zilla, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on thisJ6~ay of April, 2004, I served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Matthew S. Crosby, Esquire 1300 Linglestown Road Harrisburg, P A 17110 _&~,7~ Angela . a . 0 ...., 0 = c "'" -n ~,=, ...,.. ~oro :lC ~ ~!.'-I :1=""' rl1 :!3 -< -oFn (J) I 86 -~,., w ~,~) -{ ) -u -,-.... ---n ;.; (=-~ ~ go ~ "=U ,51""0 >c: CP. --\ "7 55 ~ c::> '-< VERONICA L. DAVIS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2003-3679 CIVIL BONNIE KELTZ and L YNN KELTZ, Defendants PRAECIPE FOR A RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule directing Plaintiff to file a Complaint in the above-referenced matter within twenty (20) days of service thereof or risk a judgment ofpon pros. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY:~------- S phen Barcavage, Esquire .0. No. 78867 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3506 Attorneys for the Defendants DATE: VERONICA L. DAVIS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2003- 2120 CIVIL BONNIE KELTZ and LYNN KELTZ, Defendants CERTIFICATE OF SERVICI!:; I, Angela Zilla, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this "'3~ay of April, 2004, I served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Matthew S. Crosby, Esquire 1300 Ling1estown Road Harrisburg, PA 17110 ~ - c..t. c ~ Angda Z' a VERONICA 1. DAVIS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2003-3679 CIVIL BONNIE KEL T2 and LYNN KEL T2, Defendants RULE AND NOW, this 3(l.cl day of (fI ';Jf foregoing Praecipe, Plaintiff is hereby ordered to file her Complaint within twenty (20) days , 2004, upon consideration of the hereof or suffer judgment of non pros. BY THE PROTHONOTARY; U-C.l?.. (') ~ -of:;: IT:'~ ' ~"7 ,'-', .r,,_' ''--~' Z{,., (f",," ~b Ji:c'. be> )..-c: :z, :< ...... <=> 5? ~ -<: , W -0 :J; ~ o o Q. ..... ::C..., "'P' -orn 136 ~:B 2M Q. ~ VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-3679 CIVIL v. CIVIL ACTION - LAW BONNIE KELTZ and LYNN KELTZ, Defendants CERTIFICATE OF SERVICE I hereby certify that true and correct copies of the Plaintiffs First Set of Interrogatories Directed to Defendant, Bonnie Keltz and tl~e Plaintiffs First Request for Production of Documents Propounded Upon Defendant, Bonnie Kletz, were served on , BONNIE KELTZ and Plaintiffs First Set of Interrogatories Directed to Defendant, Lynn Keltz, was served on LYNN KELTZ by sending a copy of the aforesaid documents to them, respectively, at their mutual address of 621 East Winding Hill Rd., Mechanicsburg, PA 17055, both by Certified U.S. Mail on May.L(, 2004, and, also, Courtesy copies of the aforementioned documents were sent to Stephen J. Barcavage, Esq.,an interested party, at Marshall, Dennehey, Warner, Coleman & Goggin, 4200 Crums Mill Rd., Suite B, Harrisburg, PA 17'112, by United States Mail, regular service, in Harrisburg, Pennsylvania on May -Ii, :W04. DATE: c;/ Iii C1 ~ERG'LLP Matthew S. Crosby, Esq. Attorney 1.0. 6!l367 1300 Linglestown Rd. Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff (J ,......, rO" ~ :--.. (= -L- ,_.....: s~: o Wi! :;1 f;tl :,lJ " "T.'In1 ~),_JC;; ',.-) j ':-,-:J~~ :~il ;~ ~;~ -< CD ~o _.~: r:? 01 -.I .);J ..< Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-3679 CIVIL VERONICA L. DAVIS, v. CIVIL ACTION - LAW BONNIE KELTZ and LYNN KELTZ, Defendants 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 Compiaint 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOOA110N 2 Uberty Avenue, Carlisle, PA 17013 Telephone 717-249-3166 or 800-990-9lO8 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificacien de esta Demanda y Aviso radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defenslls de, y objecciones a, las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar accien como se describe anteriormente, el caso puede proceder sin usted y un fallo por cuaiquier suma de dinero reclamada en ia demanda 0 cualquier otra reclamaci6n 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARPOR LOS SERVICIOS DE UN ABOGADO,ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALlFICAN CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue, Carlisle, PA 17013 Telephone 717-249-3166 or 800-990-9108 HANDLER, HlENNING & ROSENBERG, LLP By: LA-- Matthew S. Crosby, Esquire I.D.# 69367 1300 Linglestown Road, Harrisburg, PA 17110 (717) 238-2000 F :IWP Directories\JJV\ComplaintlMV A Idavis. wpd VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA NO. 2003-3679 CIVIL v. CIVIL ACTION - ILAW BONNIE KELTZ and LYNN KELTZ, Defendants COMPLAINT AND NOW, comes the Plaintiff, Veronica L. Davis, by and through her attorneys, HANDLER, HENNING & ROSENBERG, LLP, by Matthew S. Crosby, Esq., and makes the within Complaint against the Defendants, Bonnie Keltz and Lynn Keltz, as follows: 1. Plaintiff, Veronica L. Davis, is a competent adult individual currently residing at 601 Cumberland Point Circle, Mechanicsburg, Cumberland County, PA 17055. 2. Defendant, Bonnie Keltz, is an adult individual currently residing at 621 East Winding Hill Road, Mechanicsburg, Cumberland County, PA 17055. 3. Defendant, Lynn Keltz, is an adult individual currently residing at 621 East Winding Hill Road, Mechanicsburg, Cumberland County, PA 17055. 4. At all times material hereto, Plaintiff, Veronica L. Davis, was the owner and operator of a 1993 Mercury Villager, bearing New York IRegistration Number 418-42J (hereinafter, "Plaintiff's vehicle"). 5. At all times material hereto, Defendant, Bonnie Keltz, was the operator of a 1989 Pontiac Grand Prix (hereinafter, "Defendant's velhicle"), bearing Pennsylvania Registration Number DGB-7795 and owned by Defendant, Lynn Keltz. 6. At all times material heretQ, Plaintiff was insured under an autQmobile insurance PQlicy with GeicQ Insurance CQmpany and was covered by the full-tort QptiQn. 7. On or abQutAugust 10,2001, at approximately 12:24 p.m., Plaintiff, Veronica L. Davis, was stopped on Wesley Drive waiting for the vehide in frQnt .of her to turn left into Wesley Park Apartments in Cumberland CQunty, Pennsylvania. 8. At approximately that same time and place, suddenly, and without any warning, Defendant, BQnnie Keltz, who had been traveling behind Plaintiff's vehicle, viQlently struck the rear of Plaintiffs stopped vehicle. 9. As a direct and proximate result .of the negHgence of Defendants, Bonnie Keltz and Lynn Keltz, the Plaintiff, Veronica L. Davis, sustained serious and extensive injuries as set fQrth more fully below. COUNT I - NEGLIGENCE Veronica L. Davis v. Bonnie Keltz 10. Plaintiff, VerQnica L. Davis, incorporates and makes part .of this Complaint Paragraphs 1 through 9 above, as if the same were set fQrth fully below. 11. The occurrence of the aforementioned cQllisiQn and all of the resultant injuries to Plaintiff, VerQnica L. Davis, are the direct and proximate result of the negHgence .of the Defendant, Bonnie Keltz, generally and more speci'fically, as set forth below: (a) Infailing to be reasonably vigilant toO .observe the road and traffic cQnditions then and there existing: (b) In failing to .operate a vehicle in such a manner that WQuld allow her toO apply the brakes and stop before striking the rear .of Plaintiff's vehicle: 2 (c) In failing to operate a vehicle under proper and adequate control so that she could have avoided striking Plaintiffs vehiclEl; (d) In failing to properly regulate the speed of a vehicle so as to prevent a rear- end collision; (e) In failing to operate a vehicle at a speed and under such control so as to be able to stop within the assured clear distanc:e, in violation of 75 Pa. C.SA 93361 ; (f) In failing to operate a vehicle at a speed that was safe for existing conditions, in violation of 75 Pa. C.SA 933161; (g) In failing to maintain proper and adequate observation of the existing road and traffic conditions; (h) In failing to keep a proper lookout for vehic!les lawfully stopped on Wesley Drive in Cumberland County, Pennsylvania:. (i) In failing to exercise reasonable care in the operation and control of a vehicle, in violation of 75 Pa. C.SA 9 3714; and G) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in faililng to have a vehicle under such control that injury to persons or property could be avoided. 12. As a direct and proximate result of the negli!~ence of the Defendant, Bonnie Keltz, the Plaintiff, Veronica L. Davis, has suffered serious injuries, including, but not limited to, injuries to her cervical, thoracic, and lumbar spilnes; abdolllinal injuries; a large incarcerated hernia that required surgical intervention; pain and numbness in both upper extremities and in her left leg; headaches; and a cracked tooth. 3 13. As a direct and proximate result of the ne~lligence of Defendant, Bonnie Keltz, the Plaintiff, Veronica L. Davis, has suffered lost wages and will in the future continue to suffer a loss of income and/or loss of earning capacity. 14. As a direct and proximate result of the ne~lligence of Defendant, Bonnie Keltz, the Plaintiff, Veronica L. Davis, has suffered 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 physical, emotional. and financial detriment and loss. 15. As a direct and proximate result of the ne91igence of Defendant, Bonnie Keltz, the Plaintiff, Veronica L. Davis, has been compelh~d, in order to effect a cure for aforesaid injuries, to expend money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to her great detriment and loss. 16. As a direct and proximate result ofthe negligence of Defendant, Bonnie Keltz, the Plaintiff, Veronica L. Davis, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 17. As a direct and proximate result of negligence of Defendant, Bonnie Keltz, the Plaintiff, Veronica L. Davis, has been, and will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 18. Plaintiff, Veronica L. Davis, believes and, therefore, avers that her injuries are permanent in nature. 4 WHEREFORE, Plaintiff, Veronica L. Davis, seeks damages from Defendant, Bonnie Keltz, in an amount in excess of the compulsory arbitration limits of Cumberland County and demands a trial by jury. COUNT II - NEGLIGENT ENTRUSTMENT Veronica L. Davis v. Lvnn Koltz 19. Plaintiff, Veronica L. Davis, incorporates and makes part of this Complaint paragraphs 1 through 18 above, as if the same were set forth fully below. 20. The occurrence of the aforementioned collision and the resultant injuries to the Plaintiff, Veronica L. Davis, were caused directly and proximately by the negligence of Defendant, Lynn Keltz, in allowing Defendant, Bonnie Keltz, to operate her vehicle, when she knew, or should have known, of Bonnie Keltz's propensity to operate motor vehicles as set forth below: (a) Without being reasonably vigilant to observe other motor vehicles on the roadway; (b) Without properly observing existing traffic and road conditions; (c) At speeds that are unsafe for existin9 traffic and road conditions; (d) At speeds in excess of the posted speed limits; (e) Without keeping a proper lookout fOI" other vehicles; and (f) In otherwise operating motor vehiclE!S in a negligent and/or careless manner. 5 21. As a direct and proximate result of the negli!gence of the Defendant, Lynn Keltz, the Plaintiff, Veronica L. Davis, has suffered serious injuries, including, but not limited to, injuries to her cervical, thoracic, and lumbar spines; abdominal injuries; a large incarcerated hernia that required surgical intervention; pain and numbness in both upper extremities and in her left leg; headaches; and a cracked tooth. 22. As a direct and proximate result of the negligence of Defendant, Lynn Keltz, the Plaintiff, Veronica L. Davis, has suffered lost wages and will in the future continue to suffer a loss of income and/or loss of earning capacity. 23. As a direct and proximate result of the negligence of Defendant, Lynn Keltz, the Plaintiff, Veronica L. Davis, has suffered 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 physical, emotional, and financial detriment and loss. 24. As a direct and proximate result of the negli!~ence of Defendant, Lynn Keltz, the Plaintiff, Veronica L. Davis, has been compelled, in order to effect a cure for aforesaid injuries, to expend money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to hElr great detriment and loss. 25. As a direct and proximate result of the negli'gence of Defendant, Lynn Keltz, the Plaintiff, Veronica L. Davis, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 26. As a direct and proximate result of negligence of Defendant, Lynn Keltz, the Plaintiff, Veronica L. Davis, has been, and will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 6 27. Plaintiff, Veronica L. Davis, believes and, therefore, avers that her injuries are permanent in nature. WHEREFORE, Plaintiff, Veronica L. Davis, seeks damages from Defendant, Lynn Keltz, in an amount in excess of the compulsory arbitration limits of Cumberland County and demands a trial by jury. Respectfully submitted, Date: S-{ I'~ I C4 ::~NBERG.LLP Matthew S. Crosby, Esq. 1.0. No. 69367 1300 Lin~llestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff 7 VERIFICATION PURSUANT TO Pa. R.c.P. No. l024(c) MATTHEW S. CROSBY, ESQ. states that he is the attorney for the party filing the foregoing document; that he makes this Complaint as an attorney and verifies that it is correct and accurate to the best of his knowledge, information and belief and that this statement is made subject to the penalties of 18 Pa. C.S.A., Section 4904 relating to unsworn falsification to authorities. ~~~ MATTHEW S. CROSBY, ESQ. DATE: S7h/CCj CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendants, BONNIE KELTZ and LYNN KELTZ, by sending a copy of the same to them at their mutual address of 621 East Winding Hill Rd., Mechanicsburg, PA 17055, by Certified U.S. Mail on May jl, 2004, and, .also, A courtesy copy to Stephen J. Barcavage, Esq.,an interested party, at Marshall, Dennehey, Warner, Coleman & Goggin, 4200 Crums Mill Rd., Suite B, Harrisburg, PA 17112, by United States Mail, regular service, in Harrisburg, Pennsylvania on MaylL, 2004. HANDLER,HE~~ENBERG'LLP BY~ Matthew S. Crosby, Esq. Attorney 1.0. 69367 1300 Linglestown Rd. Harrisburg, PA 17110 (717) 238-2000 DATE: 5"( i<i\C4 Attorneys for Plaintiff ;~) -" -j-.: r'J ('.n ....., "-> c-~ ?= o -n :;:! i~-;' f! "f~ -.:" 5:~,-; \.0 :r".l"" ;'')J ~}~! ~{j () rn CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 08/11/2004 M~~n ~~a ~. Attorney c:' f DE11-510381 598 0 ~ -LO ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RID:.B 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 59 B 0 l-CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTH SOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, A:IID X-RAY(S) X-RAY ONLY MEDICAL, HILLING, A:IID X-RAY(S) MEDICAL, BILLING, A:IID X-RAY(S) MEDICAL, BILLING, A:IID X-RAY(S) MEDICAL, BILLING, A:IID X-RAY (S) MEDICAL, BILLING, A:IID X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, A:IID X-RAY(S) X-RAY ONLY DE02-273383 59 B 0 1 - CO 1 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULI~ 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (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 A TT ACHED RIDER .... at The MCS GrOllp Ine 1601 Market Street Snite 800 Philadelnhia PA 19101 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: ADDRESS: STEPHEN J. BARCA V AGE. ESO. 4200 CRUMS MIl.l. ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 1 1 2004 Date: ...)u 4-L'1 L :J...{)O'/ Seal of the Court '-- 59801-01 EXPLANATION OF REQUIRED Rl~CORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, 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: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBURG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SU10-515210 59801-LOl CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE:, 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 st;bpoena 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 identica.l to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08/11/2004 STEPHEN J". BARCAVAGE, ESQ. Attorney for DEFENDANT DEll-510382 5980 l - L 02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOClJMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUl.oE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. intenc~ 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGB, ESQ. Attorney for DEFENDANT CC: STBPHEN J. BARCAVAGB, ESQ. - 05000-00116 Any questions regarding this matter, contact THB MCS GROUP INC. 1601 MARKBT STRBET #800 PHILADBLPHIA, PA 19103 (215) 246 -0900 DBIl2-273383 5980 l-CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTH SOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, lIND X-RAY(S) X-RAY ONLY MEDICAL, BILLING, lIND X-RAY(S) MEDICAL, BILLING, lIND X-RAY(S) MEDICAL, BILLING, lIND X-RAY(S) MEDICAL, BILLING, lIND X-RAY{S} MEDICAL, BILLING, lIND X-RAY{S} MEDICAL RECORDS MEDICAL, BILLING, lIND X-RAY(S) X-RAY ONLY DEIl2-273383 S9801-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS lOR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (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 A IT ACHED RIDER .... at The MCS Group Ino 1601 Market Street Suite ROO Philadelnhia P A 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within 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: STEPHEN J. BARCA V AGE. ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG PA ]7110 TELEPHONE: (2]5) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: .JuL AUG 1 1 2004 ~ /91 ;:)/)D'f BY THE COURT: &b Prothonotary/Clerk, Civil Di n <..... ~O-.~.f? .7f-IA~r.-.r-- Deputy Seal of the Court 59801-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S, CT SCANS, EEG'S AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SUIO-515212 59 B 0 l-LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGI:, 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: 08/11/2004 STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT DE11-510383 5980~-L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. inten(~ 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 11800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 5980J..-COJ.. >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, Mil KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, IlNJl X-RAY(S) X-RAY ONLY MEDICAL, BILLING, IlNJl X-RAY(S) MEDICAL, BILLING, IlNJl X-RAY{S) MEDICAL, BILLING, IlNJl X-RAY(S) MEDICAL, BILLING, IlNJl X-RAY (S) MEDICAL, BILLING, IlNJl X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, IlNJl X-RAY(S) X-RAY ONLY DE02-273383 59 a 0 1-CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAl. (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 RIDER **** at The MCS Group Inc 1601 Market Street Suite ROO Phi]adelnhia PA ]9103 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: STEPHEN 1. BARCA V AGE. ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant NAME: ADDRESS: BY THE COURT: . /J A-/;;;,-) ~ Prothonotary/Clerk, Civil lliVi~ <..... ~a . Deputy AUG 1 1 2004 Date: .... )u 1'f J 9 ( "JI")O'( Seal of the Court 5980 I -03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL I II SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, 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 su.ch 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: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SU:.O-515214 59801 - L 03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ AS a prerequisite to service of a subpoena for docume:lts and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAG8, ESQ. certifies that (1) A notice of intent to serve the subpoena witi 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 b,!half of DATE: 08/11/2004 STEPHEN .1. BARCAVAGE, ESQ. Attorney for DEFENDANT DEl1-510384 59 B 0 l-LO 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. inten(jg 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 Olr by contacting our local MCS office. DATE: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DEIl2-273383S9801-COl LOCATION NAME HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED MEDICAL RECORDS &. HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS &. HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AJiD X-RAY(S) X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, j\ND X-RAY(S) MEDICAL, BILLING, j\ND X-RAY(S) MEDICAL, BILLING, j\ND X-RAY(S) MEDICAL, BILLING, j\ND X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, AND X-RAY(S) X-RAY ONLY DEll2-273383 59 a 0 l-CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Groun Inc ]601 Market Street Suite 800 Philadelnhia PA 19101 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: STEPHEN J. BARCAVAGE. ESO. 4200 CRUMS MII.I. ROAD SUITE B HARRISBURG PA 17]]0 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: , July AUG 1 1 2004 /Cf I .J. 66C.f BY THE COURT: --& Prothonotary/Clerk, Civil Divisi ~ Deputy ............ Seal of the Court 59801-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S CT SCANS, EEG'S AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray fIlms and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to aud including the preseut. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 8U:,0-515216 59801 - L 04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVA@, 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: 08/11/2004 STEPHEN .J. BARCAVAGE, ESQ. Attorney for DEFENDANT DEl1-510385 5980 l-LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. intencm 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 S980~-CO~ >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTH SOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, mID X-RAY(S) X-RAY ONLY MEDICAL, BILLING, mID X-RAY(S) MEDICAL, BILLING, JOOJ X-RAY(S) MEDICAL, BILLING, JOOJ X-RAY(S) MEDICAL, BILLING, JOOJ X-RAY (S) MEDICAL, BILLING, JOOJ X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, JOOJ X-RAY(S) X-RAY ONLY DE02-273383 59 B 0 1 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS lOR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR SlJRIR RAY (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 RIDER **** at The MCS Group Joe 1601 Market Street Suite 800 Philadelphia P A 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within 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: STEPHEN J. BARCA V AGE. ESO. ADDRESS: 4200 CRUMS MJT.! ROAD SillTE B HARRISBlIRG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: 1 L AUG 1 1 2004 ,-V Y IQ, .Jnsy BY THE COURT: -fuA ProthonotaJry/Clerk, Civil Divisi ........ /2~ P.~d4-e1V"' Deputy Seal of the Court 59801-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. SUBIR RAY 43IO LONDONDERRY ROAD HARRISBURG, PA l7I09 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S, CT SCANS, EEG'S AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limitl~d to any and all records, correspondence to and from the consulting and/or treating physicians, fIles, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBllJRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 8U10-515218 S980~-LOS CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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 ,=ach 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 th,= 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: 08/11/2004 STEPHEN ,1. BARCAVAGE, ESQ. Attorney for DEFENDANT DEl1-510386 59 B 0 1-LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCIlMBNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. intemls 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 59 a 0 1 - COol LOCATION NAME >>> LOCATION LIST <<< RECORDS REQUESTED PAGE: 1 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, Mil KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AIlD X-RAY(S) X-RAY ONLY MEDICAL, BILLING, }IND X-RAY(S) MEDICAL, BILLING, ,~ X-RAY(S) MEDICAL, BILLING, ,~ X-RAY(S) MEDICAL, BILLING, ,~ X-RAY(S) MEDICAL, BILLING, ,~ X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, ,~ X-RAY(S) X-RAY ONLY DE02-273383 S9B01-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PINNACLE COMM GEN OSTEO HOSP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by ~le court to produce the following documents or things: .... SEE ATTACHED RIDER .... at The MCS Groun Tne 1601 Market Street Suite 800 Philadelnhia PA 1'1103 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. TIllS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCA V AGE. ESO. ADDRESS: 4200 CRI JMS MIl .T. ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: AUG 1 1 7004 JuL, J 9; :)/'M'f Seal of the Court BY THE COURT: ~ Prothonotary/Clerk, Civil Div' . ~"D f?~AtuV--- Deputy '-- 59801-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE COMM.GEN.OSTEO HOSP. 4300 LONDONDERY RD. HARRISBURG, PA 17109 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S, CT SCCANS, EEG'S AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray fIlms and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBllJRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SU10-515220 5980], - L 06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 08/11/2004 STEPHEN ,J. BARCAVAGE. ESQ. Attorney for DEFENDANT DEll-510387 59801 - L 07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. intenljg 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 o:r by contacting our local MCS office. DATE: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 S9801-COl LOCATION NAME >>> LOCATION LIST <<< RECORDS REQUESTED PAGE: 1 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, Mil KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, J\ND X-RAY(S) X-RAY ONLY MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, J\ND X-RAY(S) X-RAY ONLY DE02-273383S9801-COl COMMONWEALTH OF 'PENNSYL VANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for EMILY WILLIAMS DO (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 RIDER **** at The MCS Groun Inc 1601 Market Street Suite 800 Philadelphia PA 1"101 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: STEPHEN J. BARCA V AGE. ESO. ADDRESS: 4200 CRUMS MII.r. ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: .j~UG 1 1 2004 ~ L91~ BY THE COURT~ ~ t- .!J _/!.U/~~.;J J K.Z~ Prothonotary/Clerk, Civil Divisi~ <.... ~J.~ P '7pP'A.J"'"'.. Deputy Seal of the Court 59801-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EMILY WILLIAMS, D.O. 1821 FULTON STREET HARRISBURG, PA 17102 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S ,EEG'S, CT SCANS AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limitc:d to any and all records, correspondence to and from the consulting and/or treating physicians, fIles, memoranda, handwritten notes, history and phys:ical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic fonn, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SUI0-515222S9B01-L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUB]~OENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGIl, 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: 08/11/2004 STEPHEN ,T, BARCAVAGE, ESQ. Attorney for DEFENDANT DE:L1-510388 59801 - L 08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, 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: 07/22/2004 MCS on bebalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 59 a 0 1 - C 01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTH SOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, 1\ND X-RAY(S) X-RAY ONLY MEDICAL, MILLING, 1\ND X-RAY(S) MEDICAL, BILLING, 1\ND X-RAY(S) MEDICAL, BILLING, 1\ND X-RAY(S) MEDICAL, BILLING, 1\ND X-RAY(S) MEDICAL, BILLING, 1\ND X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, 1\ND X-RAY(S) X-RAY ONLY DE02-273383 59 B 0 l-CO 1 COMMONWEALTH OFPENNSYL VANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JESSICA WII.I.IAMS M D (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 RIDER .... at The MCSGrollP Ino 1601 Market Street Suite ROO Philadelnhia PA ]9103 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: STEPHEN J. BARCA V AGE. ESO. 4200 CRIJMS MILL ROAD SlIITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant NAME: ADDRESS: AUG 1 1 2004 Date: -JuJ 'f /q I :J.tbL( .......... Seal of the Court 59801-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JESSICA WILLIAMS, M.D. P.O. BOX 60762 HARRISBURG, PA 17106 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S, EEG'S, CT SCANS AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic fIle, including but not limitl~d to any and all records, correspondence to and from the consulting and/or treating physicians, fIles, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray fIlms and tests with subsequent reports, includ~ any and all such items as may be stored in a computer database or otherwlse in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1URG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 8U10-515224S9801-L08 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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 s'lbpoena 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: 08/11/2004 STEPHEN ,J. BARCAVAGE, ESQ. Attorney for DEFENDANT DEll-510389 S980:L - L 09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. intemls 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 tbe 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-27338359801-C01 LOCATION NAME HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SOOIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTH SOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. >>> LOCATION LIST <<< PAGE: 1 RECORDS REQUESTED MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, JIND X-RAY (S) X-RAY ONLY MEDICAL, HILLING, JIND X-RAY(S) MEDICAL, BILLING, JIND X-RAY(S) MEDICAL, BILLING, JIND X-RAY(S) MEDICAL, BILLING, JIND X-RAY(S) MEDICAL, BILLING, JIND X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, JIND X-RAY(S) X-RAY ONLY DE02-273383 59 B 0 l-CO 1 COMMONWEALTH OFPENNSYL VANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SMITH RADTOl.oGY INC (Name of Person or Entity) Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: **** SEE A TT ACHED RIDER **** at The MCS GrollP Ine ]60] Market Street Snite ROO Philadelphia PA ]9103 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: STEPHEN J. BARCA V AGE. ESO. 4200 CRUMS MIl.I. ROAD SUITE B HARRISBURG PA ]7110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: ......L...l AUG 1 1 2004 .':-{ /9( ;:)rYj'f BY&:o;z) ~ ~ Prothonotary/Clerk, Civil Divisi<V '-- dAfJ'.-1fJ ,Po /Je:/J uW Deputy Seal of the Court 59801-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SMITH RADIOLOGY, INC. 1515 BRIDGE STREET NEW CUMBERLAND, PA 17070 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL CT SCANS, MRI'S, EEG'S AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $1 (){). (){) for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physi.cal reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic fo:rm, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SUIO-51522659801..-L09 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 08/11/2004 STEPHEN ,r. BARCAVAGE, ESQ. Attorney for DEFENDANT DEll-510390 59801. - L 1. 0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. inten<m 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 59801 -CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, MID X-RAY(S) X-RAY ONLY MEDICAL, HILLING, }lNJ) X-RAY(S) MEDICAL, BILLING, }lNJ) X-RAY(S) MEDICAL, BILLING, }lNJ) X-RAY(S) MEDICAL, BILLING, }lNJ) X-RAY(S) MEDICAL, BILLING, }lNJ) X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, }lNJ) X-RAY(S) X-RAY ONLY DE1l2-273383 5980 1-CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARY CUMMINGS lIT MD (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 A TT ACHED RIDER **** at TheMCSGroun Inc ]601 Market Street Suite 800 Philadelnhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within 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: STEPHEN J. BARCA V AGE. ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: '- j L AUG 1 1 2004 I '>f 19. J~ Bt::::OURT: , Prothonotary/Clerk, Civil ivis' '--- ~~'1 ~ ,f??p:;z.urU Deputy Seal of the Court 59801-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARY CUMMINGS, III, MD CUMMINGS ASSOCIATES 1617 N. FRONT ST. HARRISBURG, PA 17105 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S, EEG'S, CT SCANS AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. . Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to aud including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SUlO-515228 59801. - L 1. 0 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 08/11/2004 STEPHEN ~r. BARCAVAGE, ESQ. Attorney for DEFENDANT DEJ.1-510391 5980 l-Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTEN'1' TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUILE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, 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 rl~cord 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 11800 PHILADELPHIA, PA 19103 (215) 246-0900 DEI)2-273383 598 0 ~ - C 0 ~ ", LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS ,. HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS ,. HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, J\ND X-RAY(S) X-RAY ONLY MEDICAL, llILLING, J\ND X-RAY(S) MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL, BILLING, J\ND X~RAY(S) MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL, BILLING, J\ND X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, J\ND X-RAY(S) X-RAY ONLY DEIJ2-273383 59 B 0], - CO]. COMMONWEALTH OFPENNSYL VANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KI.INE FAMILY PRACTICE (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 A TT ACHED RIDER **** at The MCS Group Iue 1601 Market Street Suite 800 Philadeluhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. TIllS SUBPOENA WAS ISSUED AT TIlE REQUEST OF TIlE FOLLOWING PERSON: STEPHEN J. BARCA V AGE. ESO. 4200 CRIJMS MILL ROAD SlJITE B HARRISBURG PA ]71 ]0 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: .Ju..L AUG 1 1 2004 ~91 ;J~y ........... ,(141. Deputy Seal of the Court 5980]-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KLINE FAMILY PRACTICE 2601 NORTH THIRD STREET HARRISBURG, PA 17110 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S CT SCANS, EEG'S AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limit(~d to any and all records, correspondence to and from the consulting and/or treating physicians, fIles, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray fIlms and tests with subsequent reports, inc1udinll 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SUlO-515230 5980:1. -L:1.:1. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGll, 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 obj ection 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: 08/11/2004 STEPHEN .J. BARCAVAGE, ESQ. Attorney for DEFENDANT DEll-510392 59 B 0 l-L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. inten(~ 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: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-273383 59 B 0 l-CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR HAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PHACTICE HEALTH SOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS ,. HOSPITAL BILL X-HAY ONLY MEDICAL RECORDS ,. HOSPITAL BILL X-HAY ONLY MEDICAL, BILLING, ~.NIJ X-HAyeS) X-HAY ONLY MEDICAL, BILLING, ~.NIJ X-HAY(S) MEDICAL, BILLING, ~.NIJ X-HAyeS) MEDICAL, BILLING, ~.NIJ X-HAyes) MEDICAL, BILLING, ~.NIJ X-HAyes) MEDICAL, BILLING, ~.NIJ X-HAyes) MEDICAL RECORDS MEDICAL, BILLING, ~.NIJ X-HAyes) X-HAY ONLY DED2-273383 5980:1. - C 0 :1. COMMONWEALTH OF 'PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOlJTH REHAB (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 A TT ACHED RIDER .... at The MCS Grouo Toe 1601 Market Street Suite 800 Philadelphia P A 19103 You may deliver or mail legible copies of the documents or produce things. requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within 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: STEPHEN 1. BARCA V AGE. ESO. 4200 CRlJMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: J. I AUG 1 1 2004 ..... J..! ~ l't. :la6Y Seal of the Court BY THE COURT: PrO~~~/CI~k, Civil Divis' '-- 42HI-,..e .~44<PJ-- Deputy 59801-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB. 920 CENTURY BOULEVARD MECHANICSBURG, PA 17055 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S, EEG'S, CT SCANS AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. . 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: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSB1JRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 8U10-515232 59801-L12 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena at tached 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: 08/11/2004 STEPHEN ,J. BARCAVAGE, ESQ. Attorney for DEFENDANT DEl1-510393 59 B 0 l-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RIDUB 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. intenc~ to serve a subpoena identical to the one that is attached to tbis 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 twent.y 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: 07/22/2004 MCS on bebalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET .800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273383 59 B 0 ]"-CO]" >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(SJ X-RAY ONLY MEDICAL, HILLING, AND X-RAY(SJ MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(SJ MEDICAL, BILLING, AND X-RAY(SJ MEDICAL RECORDS MEDICAL, BILLING, AND X-RAY(SJ X-RAY ONLY DEIJ2-273383 59 a 0 1 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULI[ 4009.22 TO: Custodian of Records for PHYSICIAN OF REHAB. (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 A TT ACHED RIDER **** at The MCS GrOll]) Inc ] 601 Market Street Suite ROO Philadelphia P A ] 91 03 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: ADDRESS: STEPHEN 1. BARCA V AGE. ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: k, Prothonotary/Clerk, Civil Divis' '--- ~ Deputy Date: I 1 AUG 1 1 2004 Jl..t ..'-( [9, J~Y Seal of the Court 59801-13 EXPLANATION OF REQUIRED Rl~CORDS TO: CUSTODIAN OF RECORDS FOR: PHYSICIAN OF REHAB. 175 LANCASTER BLVD. P.O. BOX 2028 MECHANICSBURG, PA 17055 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ALL MRI'S, EEG'S, CT SCANS AND DIAGNOSTIC MATERIALS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physkal reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic fmm, relating to any examination, consultation, diagnosis, care or treatment perulining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBlJRG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SUlO-S1S234 59801-L13 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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 identicall to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 08/11/2004 STEPHEN ;r. BARCAVAGE, ESQ. Attorney for DEFENDANT DEll-510394 5980 1-L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AD LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Rill:.E 4009.21 [ Note: see enclosed list of locations] TO: MATTHEW CROSHY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, 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 you.r expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/22/2004 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 11800 PHILADELPHIA, PA 19103 (215) 246 -0900 DE02-273383 59 B 0 1-CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL DR. SUBIR RAY PINNACLE COMM.GEN.OSTEO HOSP. EMILY WILLIAMS, D.O. JESSICA WILLIAMS, M.D. SMITH RADIOLOGY, INC. CARY CUMMINGS, III, MD KLINE FAMILY PRACTICE HEALTHSOUTH REHAB. PHYSICIAN OF REHAB. PINNACLE COMM.GEN.OSTEO HOSP. MEDICAL RECORDS , HOSPITAL BILL X-RAY ONLY MEDICAL RECORDS , HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, ~~ X-RAY(S) X-RAY ONLY MEDICAL, I:lILLING, ~~ X-RAY(S) MEDICAL, BILLING, ~~ X-RAY(S) MEDICAL, BILLING, ~~ X-RAY(S) MEDICAL, BILLING, ~IID X-RAY (S) MEDICAL, BILLING, AIID X-RAY(S) MEDICAL RECORDS MEDICAL, BILLING, AIID X-RAY(S) X-RAY ONLY DEI~2-273383 59 a 0 ~ - C 0 ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 vs. BONNIE KELTZ AD LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PINNACLE COMM GEN OSTEO HOSP (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 RIDER **** at TheMCSGroun Inc 1601 Market Street Suite ROO Philarlelnhia fA 19'101 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 wilhin twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: STEPHEN J. BARCA V AGE. ESO. 4200 CRIJMS MILL ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant BY THE COURT: &b Prothonotary/Clerk, Civil Divi "-- ~'-" .E 7'fAI/'L../ Deputy Date: -Ju t;lc/c ~~<{ Seal of the Court 59801- EXPLANATION OF REQUIRED RE,CORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE COMM.GEN.OSTEO HOSP. 4300 LONDONDERY RD. HARRISBURG, PA 17I09 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING MRI'S, CT SCANS ,EEG'S AND/OR OTHER DIAGNOSTIC MATERIALS Please call for prior approval for fees in excess of $IOO.OO for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CffiC, MECHANICSBURG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SUIO-S1S236 S9801-L14 VERONICA L. DAVIS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003-3679 CIVIL BONNIE KELTZ and LYNN KELTZ, Defendants : CIVIL ACTION - LAW NOTICE TO PLEAD TO: Veronica L. Davis, Plaintiff c/o Matthew S. Crosby, Esquire HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be filed against you. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN ~--- BY: TEPHEN J. BARCA V AGE, ESQUIRE I.D. No. 78867 4200 Crums Mill Road Harrisburg, PA 17112 (717) 651-3506 DATE: ~il~lo~ Attorney for Defendants VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2003-3679 CIVIL BONNIE KELTZ and LYNN KELTZ, Defendants CIVIL ACTION -- LAW DEFENDANTS' ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT NOW COMES Defendants, Bonnie Keltz and Lynn Keltz, by and through their attorney, who files this response to Plaintiff's Complaint and answers the Complaint as follows: I. Denied. Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph I, and therefore, the same are denied with strict proof thereof required at trial. 2. Denied. Defendant, Bonnie Keltz, currently resides at 28 W. Willow Terrace Road, Mechanicsburg, P A 17050. 3. Admitted. 4. Denied. Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 4 and therefore, the same are denied with strict proof thereof required at trial. 5. Admitted. 6. Denied. Paragraph 6 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 6 and therefore, the same are denied with strict proofthereof required at trial. 7. Denied. Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 7 and therefore, the same are denied with strict proof thereof required at trial. 8. Denied. Paragraph 8 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. 9. Denied. Paragraph 9 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 9, and therefore, the same are denied with strict proof thereof required at trial. COUNT I - NEGLIGENCE Veronica L. Davis v. Bonnie Keltz 10. Defendants hereby incorporates by reference their answers to Paragraphs 1-9 as if fully set forth herein. 11. (a) - (j). Denied. Paragraphs 11 (a) - (j) are denied in that the same contains conclusions of law to which no response is required, therefore, strict proof is required at trial. 12. Denied. Paragraph 12 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further 2 response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 12, and therefore, the same art: denied with strict proofthereof required at trial. 13. Denied. Paragraph 13 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 13, and therefore, the same are denied with strict proofthereof required at trial. 14. Denied. Paragraph 14 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 14, and therefore, the same are: denied with strict proof thereof required at trial. 15. Denied. Paragraph 15 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 15, and therefore, the same are: denied with strict proof thereof required at trial. 16. Denied. Paragraph 16 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the 3 allegations contained in paragraph 16, and therefore, the same art: denied with strict proof thereof required at trial. 17. Denied. Paragraph 17 is denied in that the same contains conclusions of law to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth ofthe allegations contained in paragraph 17, and therefore, the same art: denied with strict proof thereof required at trial. 18. Denied. Paragraph 18 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth ofthe allegations contained in paragraph 18, and therefore, the same arf: denied with strict proof thereof required at trial. WHEREFORE, Defendants, Bonnie Keltz and Lynn Keltz, respectfully requests judgment in their favor and against the Plaintiff together with such other costs this Honorable Court deems appropriate. COUNT II - NEGLIGENT ENTRUSTMENT Veronica L. Davis v. Lvnn Keltz 19. Defendants hereby incorporates by reference their answers to Paragraphs 1-18 as if fully set forth herein. 20. (a) - (f). Denied. Paragraphs 20 (a) - (f) are denied in that the same contains conclusions of law to which no response is required, therefore, strict proof is required at trial. 4 21. Denied. Paragraph 21 is denied in that the same contains conclusions of law to which no response is required, therefore, strict proof is required alt trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 21, and therefore, the same are denied with strict proof thereof required at trial. 22. Denied. Paragraph 22 is denied in that the same contains conclusions of law to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 22, and therefore, the same are denied with strict proof thereof required at trial. 23. Denied. Paragraph 23 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 23, and therefore, the same are denied with strict proof thereof required at trial. 24. Denied. Paragraph 24 is denied in that the same contains conclusions of law to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 24, and therefore, the same are denied with strict proof thereof required at trial. 5 25. Denied. Paragraph 25 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth ofthe allegations contained in paragraph 25, and therefore, the same are denied with strict proof thereof required at trial. 26. Denied. Paragraph 26 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth ofthe allegations contained in paragraph 26, and therefore, the same are denied with strict proof thereof required at trial. 27. Denied. Paragraph 27 is denied in that the same contains conclusions oflaw to which no response is required, therefore, strict proof is required at trial. By way of further response, Defendants lack knowledge sufficient to form a believe as to the truth of the allegations contained in paragraph 27, and therefore, the same are denied with strict proof thereof required at trial. WHEREFORE, Defendants, Bonnie Keltz and Lynn Keltz,. respectfully requests judgment in their favor and against the Plaintiff together with such other costs this Honorable Court deems appropriate. NEW MATTER 28. Defendants hereby incorporates by reference their answers to Paragraphs 1-27 as if fully set forth herein. 6 29. Plaintiff's claims are barred by the applicable statute of limitations. 30. Plaintiff has failed to state a cause of action upon which relief can be granted. 31. Plaintiff's claims are barred and/or limited by all applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 32. No act or omission on the part of Defendants was a substantial or contributing factor in bringing about Plaintiff's alleged injuries and/or damages, all such irUuries and/or damages being expressly denied. 33. Any and all injuries and or damages as described by Plaintiff in her Complaint, the same being expressly denied, were caused in whole or in part by the acts or omissions on the part of Plaintiff and/or others over whom Defendants had no control nor right of control. 34. Plaintiff's claims are barred and/or limited by the doctrine of res judicata and/or collateral estoppel. 35. Plaintiff's claims are derivative in nature and are barred as a matter of/aw. 36. Defendants breached no duty of care owed to Plaintiff under the circumstances. 37. Plaintiff's claims are barred and/or limited by the Ptlnnsylvania Comparative Negligence Act. 38. Plaintiff's claims are barred and/or limited by the applicable provisions ofthe Pennsylvania Worker's Compensation Act. 39. At all times material hereto, Defendants acted in a safe, legal and non-negligent manner. 40. Plaintiff's Complaint and/or claims are barred by her selection of limited tort on the applicable automobile insurance policy as set forth by 75 Pa.C.S.A. 91705. 7 WHEREFORE, Defendants, Bonnie Keltz and Lynn Keltz, respectfully requests judgment in their favor and against the Plaintiff together with such other costs this Honorable Court deems appropriate. MARSHALL, DENNBHEY, WARNER, COLEMAN & GOGGIN BY: EPHEN J. BARCA V AGE, ESQUIRE LD. No. 78867 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3506 DATE: 'bIll; ID+ Attorneys for Defendants 8 VERIFICATION The undersigned hereby verifies that the statements in the foregoing Answer with New Matter to Plaintiffs Complaint are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the: preparation ofthe defense of this lawsuit. The language of the Answer with New Matter to Plaintiffs Complaint is that of counsel and not my own. I have read the Answer with New Matter to Plaintiffs Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents ofthe Answer with New Matter to Plaintiffs Complaint are that of counsel, I have relied upon my counsel in making this verification. The undersigned also understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~;i~ BY: . " _Q . ONNIE KELTZ . DATE: VERIFICATION The undersigned hereby verifies that the statements in the foregoing Answer with New Matter to Plaintiffs Complaint are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of the defense of this lawsuit. The language of the Answer with New Matter to Plaintiffs Complaint is that of counsel and not my own. I have read the Answer with New Matter to Plaintiffs Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Answer with New Matter to Plaintiffs Complaint are that of counsel, I have relied upon my counsel in making this verification. The undersigned also und'~rstands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. -il/r" ) BY: , L KEL Z DATE: 7- 3~ol{ VERONICA L. DAVIS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003-3679 CIVIL BONNIE KELTZ and LYNN KELTZ, Defendants CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Susan M. Williams, an employee of Marshall, Dennehey, Wamer, Coleman & Goggin, do hereby certify that on this J ~ +" day of August, 2004, I serve:d a true and correct copy of the foregoing document via regular mail, postage pre-paid as follows: Matthew S. Crosby, Esquire HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, P A 17110 ~~({ .U)~~ SUSAN M. WILLIAMS ...., ~>~:3 0 ..;::_ .-'1'1 -< .~ 0) to, '.."t -...; VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-3679 CIIVIL v. CIVIL ACTION - L.AW BONNIE KELTZ and LYNN KELTZ, Defendants PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER AND NOW, comes the Plaintiff, VERONICA L. DAVIS, by and through her attorneys, HANDLER, HENNING & ROSENBERG, LLP, by Matthew S. Crosby, Esq., and answers as follows to Defendants' New Matter: 28. Paragraph 28 is one of incorporation and, therefore, no response is required. 29. Denied. It is specifically denied that Plaintiff's claims are barred by the Statute of Limitations. In addition, these allegations contain conclusions of law to which no response is required. If a response is judlicially determined to be required, the averments contained therein are specifically denied. 30. Denied. The allegations in Paragraph 30 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. -1- 31. Denied. The allegations in Paragraph 31 contain conclusions of law to which no response is required. If a response is judidally determined to be required, the averments contained therein are specifically denied. 32. Denied. The allegations in Paragraph 32 are denied, pursuant to Pa. C.P. Rule 1029(e). By way of further response, to the extE!nt that the allegations contained in Paragraph 32 are conclusions of law, no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 33. Denied. The allegations in Paragraph 33 are denied, pursuant to Pa. C.P. Rule 1029(e). By way of further response, to the extent that the allegations contained in Paragraph 33 are conclusions of law, no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 34. Denied. The allegations in Paragraph 34 contain conclusions of law to which no response is required. If a response is judidally determined to be required, the averments contained therein are specifically denied. 35. Denied. The allegations in Paragraph 35 contain conclusions of law to which no response is required. If a response is judidally determined to be required, the averments contained therein are specifically denied. -2- 36. Denied. The allegations in Paragraph 36 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 37. Denied. The allegations in Paragraph 37 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 38. Denied. The allegations in Paragraph 38 contain conclusions of law to which no response is required. If a response is judic:ially determined to be required, the averments contained therein are specifically denied. 39. Denied. The allegations in Paragraph 39 are denied, pursuant to Pa. C.P. Rule 1029(e). By way of further response, to the extent that the allegations contained in Paragraph 39 are conclusions of law, no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 40. Denied. Plaintiff has not selected the limited-tort option, as averred in Paragraph 40; therefore, the allegations in Paragraph 40 are specifically denied and, also, are denied pursuant to Pa. C.P. Rule 1029(e). By way of further response, to the extent that the allegations contained in Paragraph 40 are conclusions of law, no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. -3- WHEREFORE, Plaintiff respectfully requests that this Honorable Court deny Defendants' allegations and enter judgment in favor of the Plaintiff. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Date: 'ill \8'{DL By: - Matthe S. Crosby, Esq. Attorney I.D. # 69367 1300 Linglestown Rd. Harrisburg, PA 17106 (717) 23EI-2000 Attorneys for Plaintiff -4- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendants, BONNIE KELTZ and LYNN KELTZ by sending a copy of the same to their counsel of record, STEPHEN J. BARCAVAGE, Esq., 4200 Crums Mill Rd., Harrisburg, PA 17112, by United States Mail, regular service, in Harrisburg, Pennsylvania on August ri 2004. HANDLER, HENNIING & ROSENBERG, LLP By - thew S. Crosby, Esq. Attorney I.D. #69367 1300 Linglestown Rd. Harrisburg, PA 17110 (717) 238-2000 DATE:~1 Attorneys fo r Plaintiff VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2003-3679 BONNIE KELTZ and LYNN KELTZ, Defendants CIVIL ACTION. LAW CERTIFICATE OF SERVICE AND NOW, this ;)8 'f<, day of , 2005, I hereby certify that I have, on this date, served the within Plaintiff's An rs to the Interrogatories of Defendants, Bonnie Keltz and Lynn Keltz, by sending a true and correct copy of same to their attorney of record and including copies to all parties of interest via first class mail, postage prepaid, as follows: Stephen J. Barcavage, Esquire MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 Crums Mill Road, Suite B Harrisburg, PA 17112. HANDLER, H ROSENBERG, LLP By Matthew S. Crosby, Esq. Attorney I.D. #69367 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff ,;.,;',fe .,. ,.." C~:) 2j~ :i:"'" C"-' (1"') I "-, ~ l'V U) VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2003-3679 BONNIE KELTZ and LYNN KELTZ, Defendants CIVIL ACTION - LAW CERTIFICATE OF SERVICE . t<-. d'l AND NOW, this _ (j day of J\...-.-~ ,2005, I hereby certify that I have, on this date, served the within Plaintiff's Res onses to the Request for Production of Documents of Defendants, Bonnie Keltz and Lynn Keltz, by sending a true and correct copy of same to their attorney of record and including copies to all parties of interest via first class mail, postage prepaid, as follows: Stephen J. Barcavage, Esquire MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 ROSENBERG, LLP By Matthew S. Crosby, Esq. Attorney 1.0. #69367 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff ,.-..";-.'" ';\^';:i,:L;;;;~;'"l.',lfm!;,n;","."'"" o. r;")' '" ':;;r; :~~:~trl~~,~~~~~fg~~-;~;!t:' l'-_:/o f:::?; CJl () ~n :-:-.1 :c-"" c: l,,:;;' I I.....) -;-, ('0' c.,. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 08/08/2005 . 75~ 5- V GE, ESQ. NDANT DEll-577394 59801 - L 15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL MEDICAL RECORDS X-RAY ONLY TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, 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 ~xpense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/18/2005 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-306802 S9801-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 CIVIL vs. BONNIE KELTZ AND LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (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 RIDER .... at TheMeS Groun Inc 1601 Market Street Suite 800 Philadelnhia PA 19103 You may deliver or mai11egib1e 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: STEPHEN J. BARCA V AGE. ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: --JuL'j ,:J I .;:> tYI._t;. Seal of the Court 59801-01 EXPLANATION OF REQillRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire :hospital 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, test, 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: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBURG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SU10-574460 59B01-L15 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 08/08/2005 STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT DEll-577395 5980 l-L16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL MEDICAL RECORDS X-RAY ONLY TO: MATTHEW CROSBY, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN J. BARCAVAGE, 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 ~xpense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/18/2005 MCS on behalf of STEPHEN J. BARCAVAGE, ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-306802 59801 -C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 CIVIL vs. BONNIE KELTZ AND LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (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 RIDER **** at The MCS Grouo Ioc ]60] Market Street Suite 800 Philadelohia PA 19103 You may deliver or mai11egib1e 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: STEPHEN J. BARCA V AGE. ESO. 4200 CRUMS MILL ROAD SIDTE B HARRISBURG. PA 17110 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: -Ju.L{ lJ.j d.()t;.,S' '--- Seal of the Court 5980]-02 EXPLANA TION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING MRI'S, CT SCANS, EEG'S, DIAGNOSTIC TESTING. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBURG, PA 17055 Social Security #: 052-56-0843 Date of Birth: 11-20-1961 SU10-574462 S980l-Ll6 ~ ~. -oi~-: rt'I(' -'.J' ~:!~ C:_ <,. ~~~ ~ ,..., = = Gr> ~ G'> ~ ,~ -U ~a ; ~ }j5 c:> '< U. ~. " VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-3679 CIVIL v. CIVIL ACTION - LAW BONNIE KELTZ and LYNN KELTZ, Defendants PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Matthew S. Crosby, Esq., counsel for the Plairtiffin the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of Plaintiff in the action is $35,000. 3. The counterclaim ofthe Defendant is $8,500. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: Stephen J. Barcavage, Esq., counsel for the Defendants WHEREFORE, Plaintiff prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. mitted, NNING & ROSENBERG, LLP BY: ORDER OF COURT AND NOW, this 9th day of May, 2006, in consideration of the foregoing petition, , Esq. and , Esq. and Esq. are appointed arbitrators in the above-captioned action, as prayed for. BY THE COURT: J. ~., ... CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendants, BONNIE KELTZ and LYNN KELTZ, by sending a copy of the same to their counsel of record, Stephen J. Barcavage, Esq., at Marshall, Dennehey, Warner, Coleman & Goggin, 4200 Crums Mill Rd., Suite B, Harrisburg, PA 17112, by United States Mail, regular service, in Harrisburg, Pennsylvania on May ~, 2006. & ROSENBERG, LLP By Matthew S. Crosby, Esq. Attorney 1.0. 69367 1300 Linglestown Rd. Harrisl'urg, PA 17110 (717) 238-2000 DATE:~ Attorneys for Plaintiff ~ (::) ~ '-.... }::J \ 0( "-> 0 = c.-:l ." it- <::1"' .-f D ::E: :r:." ::I.> nl, () -< -0 fTl ""-... lJ :IJ '? -U O""l (:::;Q ~ f'- -0 :'_:r~ ~1 ~ (-) --- ~ F- ::Jll: ".>"0 c5m W - );! ~ .. - .- 0 :n !2 ::--=1 -< '-<. C- t'--. -Z ~ . ~ -." VERONICA L. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-3679 CIVIL v. CIVIL ACTION - LAW BONNIE KELTZ and LYNN KELTZ, Defendants PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Matthew S. Crosby, Esq., counsel for the Plairtiffin the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of Plaintiff in the action is $35,000. 3. The counterclaim of the Defendant is $8,500. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: Stephen J. Barcavage, Esq., counsel for the Defendants WHEREFORE, Plaintiff prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. BY: ORDER OF COURT CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 \ ,~' "';/"'} t,:' Vi lib/iVAL IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, CUMBERLAND -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 05/16/2006 41 Mc~~a~ ~4~~~VAGE' E Attorney for DEFENDANT DEll-626253 S980~-L~7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 CIVIL vs. BONNIE KELTZ AND LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COMM OSTEOPA THIe HOSPITAL (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 A IT AClffin RIDER ........ at The MCS Gmqp Ino 1601 Market Street Suite 800 Fhiladelnhia FA 19103 You may deliver or mai11egib1e 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: STEPHEN J. BARCA V AGE. ESO. ADDRESS: 4200 9RUMS MTT.T. ROAD SUITE R HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: AITORNEY FOR: Defendant ivision Date: ~ ;)'-/ . 'J.Ddc. , Deputy Seal of the Court 59801-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMM. OSTEOPATHIC HOSPITAL 4300 WNOONDERRY RD. PO BOX 15128 HARRISBURG, PA 17105 RE:59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Fntire hospital 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, medicationI prescription records, wrse's notes, doctor's comments, dietary restrictions, and all ~ consent or refusal of treJltmP.nt, procedures, test, 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, re~ to any eJ[ll111inllt1nn. consultation, dillgJlOSis, care, trelItmP.nt, lltImi"",l1Il, discharge, or emergency care pertlliniT1g to: Dates Requested: up to and includiDg the present. Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBURG, PA 17055 Social Security I: XXX-XX-0843 . Date of Birth: 11-20-1961 SUI0-618606 59 B 0 1-L17 CBRTIFICATE PRBRBQUISITB TO SERVICB OF A SUBPOBNA PURSUANT TO RULB 4009.22 alllGlAt1L IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, CUMBERLAND -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 05/16/2006 /l7'cd, b~}A ~~~~GE, ES Attorney for DEFENDANT DEll-626254 5 98 0 1 - L 18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ NOTICE OF INTENT TO SBRVB A SUBPOENA TO PRODUCE DOCOMBNTS AND THINGS FOR DISCOVERY PURSUANT TO RULB 4009.21 COMM. OSTBOPATHIC HOSPITAL COMMUNITY GBNERAL OSTEOPATHIC COMMUNITY GBNERAL OSTBOPATHIC MEDICAL RBCORDS BILLING ONLY X-RAY ONLY TO: MATTHBW CROSBY, BSQ., PLAINTIFF COUNSBL MCS on behalf of STBPHBN J. BARCAVAGB, BSQ. 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. DATB: 04/26/2006 MCS on behalf of STBPHBN J. BARCAVAGB. ESQ. Attorney for DEFENDANT CC: STEPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADBLPHIA, PA 19103 (2l5) 246~Q9QQ DE02-330468 S980:L-CO:L COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 CIVIL vs. BONNIE KELTZ AND LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COMMUNITY GENERAL OSTEOPATHIC (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 ATI ACHFD RIDER .... at The MCS Grolln Tnc 1601 Market Street Suite 800 Fhiladelnhia FA 19]03 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 TIlE REQUEST OF TIlE FOLLOWING PERSON: NAME: STEPHEN J. BARCA V AGE. ESO. ADDRESS: 4200 CRUMS MIl.r, ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: , ATIORNEY FOR: Defendant ivision Date: 4n; l J, LJ ;) /y.L , Deputy Seal of the Court 59801-18 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL BIlliNG DEPT. 4300 WNGODBERRY RD. HARRISBURG, PA 17109 RE:59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all billing, insurance claims, payments, outo:tM1rl~ and/or delinquent invoices, including any and all such items as may be stored m a computer database or otherwise in electronic form, relating to any elfamination, consultation, diaglV'sis, care or tteatment pertainiTtg to: Dates Requested: up to and indudiDg the present. Subject: \1ER.ONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBURG, PA 17055 Social Security #: XXX-XX-0843 Date of Birth: 11-20-1961 SUIO-618608 59 a 0 1-L1 a CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, CUMBERLAND -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN J. BARCAVAGE, 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: 05/16/2006 ~- DEll-626255 59801-L19 COMMONWEALTH OF ~ENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS VERONICA L. DAVIS TERM, -VS- CASE NO: 2003-3679 CIVIL BONNIE KELTZ AND LYNN KELTZ NOTICE OF :IHTBNT TO SERVE A SUBPOENA TO PRODUCE DOCOMBNTS AND THINGS FOR DISCOVERY PORSUANT TO RULE 4009.21 COMM. OSTEOPATHIC HOSPITAL COMMUHITY GBNERAL OSTBOPATHIC COMMUHITY GBNERAL OSTBOPATHIC MEDICAL RBCORDS BILLING ONLY X-RAY ONLY TO: 'MATTHBW CROSBY, BSQ., PLAINTIFF COUNSBL MCS on behalf of STEPHBN J. BARCAVAGB, BSQ. 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. DATB: 04/26/2006 MCS on behalf of STEPHBN J. BARCAVAGB, BSQ. Attorney for DEFENDANT CC: STBPHEN J. BARCAVAGE, ESQ. - 05000-00116 Any questions regarding this matter, contact THE MCS GROUP INe. 1601 MARKET STREBT 1800 PHILADELPHIA, PA 19103 (2l5) 246~0'00 DE02-330468 S9801-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERONICA L. DAVIS FileNo. 2003-3679 CIVIL vs. BONNIE KELTZ AND LYNN KELTZ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COMMUNITY GENERAL OSTEOPATHIC (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 ATIACHEO RIDER .... at The MCS Groun Ine 1601 Market StreeL Suite 800 Philadelnhia FA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. TInS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN J. BARCA V AGE. ESO. ADDRESS: 4200 CRUMS Mrr.r, ROAD SUITE B HARRISBURG P A 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATIORNEY FOR: Defendant Date: ~l ~l../ ;} /")6 (,... I Seal of the Court Deputy 59801-19 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL- RADIOLOGY DEPT. 4300 WNDONBERRY RD. HARRISBURG, PA 17109 BE: 59801 VERONICA L. DAVIS Prior approval is required for fees in excess of $100.00 for hospitalS, $50.00 for all other providers. INCLUDING MRI'S, cr SCANS, EEG'S, DIAGNOSTIC TESTING PERFORMED. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present, Subject: VERONICA L. DAVIS 601 CUMBERLAND POINT CIRC, MECHANICSBURG, PA 17055 SodaI Security #: XXX-XX-0843 Date of Birth: 11-20-1961 SUI0-618610 5980 1-L19 (} c" ,"'-" ~\:~-;:\ rr\; ~-.? -' ~' ~; r:' ""eo. -r-,- .'" -~{<f:':) )-.C' 9 ",,, (.f'" ;:>: ~ .- cP -2 Q, ~~ ..,.,CD) -\~<.- (") (~) ~;:'1A'l ._;--1:"\ Q<;), 6'" .,.~ ~ --0 -;5; 8 J;' .....l l/e YO;tl <~ L. l)A--J'l.J Plaintiff ~~~l.L l:el'}; In The Court of Common Pleas of Cumberland County, Pennsylvania No. ~#? - $ <. 7 ? Defendant Civil Action - Law. Oath We do solemnly swear (or affinn) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fi elity. I d '+/fA,,, S Il..~ Name (Chairman) I ~/^' {.II""; ~c:'~ Law Firm fA $:' hit'S, Address ~WJ~7f-~ futt.vv. k .' bo...l(((l7 L (;r,f{;. Name Name A~ l kuJult1h:c Law Firm .31 P ~ ./-ttL()CVt% s:.t-. Address ~r ,rff (' ~ t!sSd cf<:Pf-r ) Law Firm dOc Al H rMrlVtC sr. Address Gd."~lL ,fa 17~J3 CtLrlrllc, PA 1(0/3 (!Ovl,'sJL- trJ I ?IJ)} City, Zip City, Zip City, Zip -JI. .. IOD~ 1ft '1I5t.l ..". II'-fDB Award We, the undersigned arbitrators, having been dilly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) W~ h"v/j /41 r~~ ~ P'C""./A./Tlrr /1\; ~ A?vdUN'T ev- f(#~(.~ 7Jdz:n.Lf~~ ;:;t/~ IluAJtJ~", q" ~//~ (1fiI/'L,'5'04) ~U~ Date of Hearing: 9t1lc~ Date of Award: ql.r(o<. . Arbitrator, dissents. (Insert name if applicable.) Arbitrators' compen~ation to be paid upon appeal: $ OlqD. DO By: Deputy Copies ma.JaJ ~ ~ ~w S. Crosb.f I Estt. ~~nJ ~~e.E&t.. Q-5-0(p Sent- -10 C A DKB r~._1 c:.::;. {:::~) c;'"'\. C.,'~I r-'~; I Ul c.") .r;- VERONICA L. DAVIS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003-3679 CIVIL BONNIE KELTZ and L YNN KELTZ, Defendants : CIVIL ACTION - LAW PRAECIPE TO SATISFY. DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-referenced matter as SATISFIED, DISCONTINUED and ENDED with Prejudice. HANDLER, HENNING & ROSENBERG, LLP DATE: \I t ~ tb /P BY: /)--- Matthew S. Crosby, Esquire Attorney J.D. No.: 69367 1300 Linglestown Road Harrisburg, P A 17110 (717) 238-2000 Attorney for Plaintiff, Veronica L. Davis ~ , . , ... VERONICA L. DAVIS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2003-3679 CIVIL BONNIE KELTZ and LYNN KELTZ, Defendants : CIVIL ACTION - LA W CERTIFICATE OF SERVICE I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this q"th day of November, 2006, I served a true and correct copy of the Praecipe to Satisfy, Discontinue and End, via regular mail, postage pre-paid as follows: Matthew S. Crosby, Esquire HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg,PA 17110 ~v4A I~l U)~A~ SUSAN M. WILLIAMS n c~~ r-:i C:..::') --, ~;, .. ~ c~ """"~ <:..r1 :c.... -'~;:... -:r'"" o c...)