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HomeMy WebLinkAbout07-2784IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff vs. JOSEPH K. CHIARA 513 South 3`d Street Lemoyne, PA 17043 Defendant File No. (? / 7 ?f44 Civil Action - PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please issue summons in and against Joseph K. Chiara in the above case. X Writ of Summons shall be issued and forwarded to Sheriff. Signature o Attorney _-Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire Pecht & Associates 55 West Hiah Street Elizabethtown, PA 17022 (717) 367-2800 Name/Address/Telephone Number of Attorney Date: --a ? Supreme Court ID Number 56304 and 38904 WRIT OF SUMMONS IN CIVIL ACTION TO: Joseph K Chiara YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. D Prothonotary/Clerk, Civil Divisi Date: atj ?, c? Qd 7 by Gttiu.? Depu \D (-) - P. ? O -- y ? 1 ?fT1 --i t- 4- L6 N Q n 1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-02784 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SAUERWINE JAMES H ET AL VS CHIARA JOSEPH K R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CHIARA JOSEPH K but was unable to locate Him in his bailiwick. WRIT OF SUMMONS , He therefore returns the the within named DEFENDANT CHIARA JOSEPH K NOT FOUND , as to 513 SOUTH 3RD STREET LEMOYNE, PA 17043 DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS. BELIEVED TO BE LIVING AT 113 SHETLAND DR HUMMELSTOWN. Sheriff's Costs: Docketing 18.00 Service 14.40 Not Found 5.00 Surcharge 10.00 Postage .41 Otlvi (4, ? 47.81 So answers.------7-- R. Thomas K ine Sheriff of Cumberland County PECHT & ASSOCIATES 05/21/2007 Sworn and Subscribed to before me this day of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff VS. JOSEPH K. CHIARA 513 South 3rd Street Lemoyne, PA 17043 Defendant File No. 0'1- 6L-78q C?v"Te y& Civil Action - PRAECIPE FOR REISSUE OF WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Please reissue summons in and against Joseph K. Chiara in the above case. X Writ of Summons shall be issued and forwarded to Sheriff. of Attorney - Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire _Pecht & Associates 55 West High Street Elizabethtown, PA 17022 (717) 367-2800 Name/Address/Telephone Number of Attorney Date: 6 1a Supreme Court ID Number 56304 and 38904 REISSUED WRIT OF SUMMONS IN CIVIL ACTION TO: Joseph K. Chiara YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. AOUW4? Prothonotary/Cler Civil Division Date: 5 711007 by I7 Deputy _ ? 000 p ? ? . _ CO ip i? Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff, vs. FILE NO. 07-2784 Civil Term JOSEPH K. CHIARA 513 South 3rd Street Lemoyne, PA 17043 Defendant. PRAECIPE FOR ENTRY OF ONCE TO: THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Please enter the appearance of Randall G. Gale, Esquire, THOMAS, THOMAS & HAFER, LLP as the attorney for the Defendant JOSEPH K. CHIARA, in the above-captioned matter. Respectfully submitted, THOMAS THOMAS & HAFER, LLP By Randall G. Gale, Esquire Attorney No. 26149 305 North Front Street, 6th FL P.O. Box 999 Harrisburg, PA 17108-0999 717-255-7648; Fax: 717-237-715 rgale@tthlaw.com CERTIFICATE OF SERVICE I, Randall G. Gale, Esquire, Attorney for Defendants, hereby certify that a copy of the foregoing Entry of Appearance was served upon the Plaintiff this /87 day of '2007, by enclosing a true and correct copy in envelopes, postage prepaid, and depositing same in the United States Mail at Harrisburg, Pennsylvania on the following: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP By cz R all G. Gale, Esquire 523680.1 ?? -n SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-02784 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SAUERWINE JAMES H ET AL VS CHIARA JOSEPH K R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: CHIARA JOSEPH K but was unable to locate Him deputized the sheriff of DAUPHIN serve the within WRIT OF SUMMONS County, Pennsylvania, to On September 26th , 2007 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answer- /- Docketing 18.00 ?--°`"- Out of County 9.00 Surcharge 10.00 R.' Thomas Kline Postage .99 Sheriff of Cumberland County 37.99 f tel"611) 1 ?. 09/26/2007 PECHT & ASSOCIATES Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. W -In The Court of Common Pleas of Cumberland County, Pennsylvania James H. Sauerwine and Arlene B. Sauerwine vs. Joseph K. Chiara Serve: Joseph K. Chiara No. 2007-2784 Civil Term Now, August 30, 2007, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, , 20 , at o'clock M, served the within upon at by handing to, a and made known to Sworn and subscribed before me this day of 120_ copy of the original So answers, Sheriff of COSTS SERVICE $ MILEAGE_ AFFIDAVIT the contents thereof. County, PA v (Pifia, of #4le "?5h-erfff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin • SAUERWINE JAMES H • CHIARA JOSEPH K V3 Sheriff's Return No- 1263-T - - -2007 OTHER COUNTY NO. 2007 2784 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy AND NOW: September 17, 2007 at 2:20PM served the within REISSUED SUMMONS CHIARA JOSEPH K to CARLA DILLER GIRLFRIEND upon by personally handing 1 true attested copy(ies) of the original REISSUED SUMMONS and making known to him/her the contents thereof at 113 SHETLAND DRIVE HUMMELSTOWN, PA 17036-0000 Sworn and subscribed to ,efore me this 18TH day of SEPTEMBER, 2007 11 1A-- C./ NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2010 So Answers, ? W,;? Sheriff of Dauphin County, Pa. ? ? 'k ... By Deputy Sheriff Sheriff's Costs:$37.25 PAID BY COUNTY SCHAEF Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant. FILE NO. 07-2784 Civil Term CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoenas with a copy of the Subpoenas attached thereto was mailed to Plaintiffs' counsel on 9/28/07; (2) a copy of the Notice of Intent, including the proposed Subpoenas, is attached to this certificate; (3) Plaintiffs' counsel has indicated he has no objection to the proposed Subpoenas and is willing to waive the remainder of the 20-day notice period in order to expedite receipt of the records; and (4) the Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent to serve the Subpoenas. THOM HOMAS & HAFER, LLP t ? R ALL G. GALE, ESQUIRE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: jU -ll--0 7 I Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, FILE NO. 07-2784 Civil Term Plaintiffs vs. JOSEPH K. CHIARA Defendant NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND"THINGS FOR :DISCOVERY PURSUANT TO RULE 4009.21 TO: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 Defendant intends to serve subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. THOMA THOMAS &HAFER, LLP / / '( 7 1, RAN.DALL G. GALE, ESQUIRE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: I-,-2F _6 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Orthopedic Institute of Pennsylvania 3399 Trindle Road, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records reports treatment notes correspondence, diagnostic studies, radiology films testing results bills insurance forms medication/prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form relating to the care and treatment of James Sauerwine d/o/b: 12/7/49, SSN 201- 40-1242 at: Thomas Thomas & Hafer. LLP 305 N. Front St. P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Harrisburg Hospital 111 South Front Street, Harrisburg, PA 17101 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records for inpatient or outpatient or clinic care including reports, treatment notes, correspondence, diagnostic studies, radiology films, testing results. bills. insurance forms, medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine d/o/b: 12/7/49 SSN 201-40-1242 at: Thomas, Thomas & Hafer. LLP, 305 N. Front St., P.O. Boa 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE vs. Plaintiff, JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Tristan Associates 4518 Union Deposit Road, Harrisburg, PA 17111 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports treatment notes correspondence diagnostic studies radiology films, testing results bills insurance forms medication/prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine d/o/b• 12/7/49 SSN 201- 40-1242 at: Thomas, Thomas & Hafer, LLP, 305 N. Front St. P.O. Box 999, Harrisburg PA 17108-0999 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seat of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Vs. Plaintiff, JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Pennsylvania Open MRI 5400 Chambers Hill Road, Harrisburg, PA 17111 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes correspondence, diagnostic studies radiology films, testing results bills insurance forms medication4prescr_ption information including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, d/o/b: 12/7/49. SSN 201- 40-1242 at: Thomas, Thomas & Hafer, LLP, 305 N. Front St. P.O. Boa 999, Harrisburg. PA 17108-0999 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. NO. 07-2784 CIVIL ACTION - LAW JOSEPH K. CHIARA Defendant. JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Lancaster Neuroscience & Spine Associates 1671 Crooked Oak Drive, Lancaster, PA 17601 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes, correspondence, diagnostic studies, radioloy films, testing results, bills, insurance forms. medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, d/o/b: 12/7/49, SSN 201- 40-1242 at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg. PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: BY THE COURT: Seal of the Court Deputy Prothonotary/Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE vs. Plaintiff, JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, James Blacksmith, D.O. 689 Yorktown Road, Lewisberry, PA 17339 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes, correspondence, diagnostic studies, radiology films, testing results, bills, insurance forms, medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form. relatiniz to the care and treatment of James Sauerwine, d/o/b: 12/7/49, SSN 201- 40-1242 at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999. 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. T141S SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Westfield Group P. O. Box 3010, Lancaster, PA 17604-3010 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A complete copy of the claim file, including any and all documents, medical records, photographs, billing information, application for benefits form, first party benefits payout sheet, disability statements, work notes, medical bills, transcripts of recorded statements, and any other information contained in your file regarding James Sauerwine, d/o/b: 12/7/49, SSN 201-40-1242. Claim #: CWP 3440920-050905, date of loss: 5/9/05 at: Thomas. Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE 1, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP R NDALL G. GALE, ESQUIRE Date: 534707.1 CERTIFICATE OF SERVICE 1, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP / i RA LL G. GALE, ESQUIRE Date: [ ? r `C ,6 7 C"' ? Q ?r?. ?,?' - fi . . rte . ? ? "? 4 7 '_ . ?_:} (? s:.. ? " ? ? p?., ^? w Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE And ARLENE B.SAUERWINE FILE NO. 07-2784 Civil Term 217 Allendale Way Camp Hill, PA 17011 Plaintiff, vs. JOSEPH K. CHIARA 513 South 3rd Street Lemoyne, PA 17043 Defendant. TO: PROTHONOTARY Cumberland County One Courthouse Square Carlisle, PA 17013-3387 PRAECIPE FOR RULE TO FILE COMPLAINT Please issue a Rule directing Plaintiffs, JAMES H. SAUERWINE and ARLENE B. SAUERWINE to file a Complaint against Defendant Joseph K. Chiara within twenty (20) days after service of the Rule or suffer Judgment of Non Pros. THOMAS, THOMAS & HAFER, LLP By R all G. Gale, Esquire Attorney No. 26149 305 North Front Street, 6d' Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7648; Fax: 717-237-7105 ?7 RGALE@TTHLAW.COM Dated: 021Z "0 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE, Attorney for Defendant Joseph K. Chiara, do hereby certify that a copy of the foregoing document was served upon the following by enclosing a true and correct copy in envelopes addressed as follows, postage prepaid, and depositing same in the United States Mail at Harrisburg, Pennsylvania on the of P/4//66 '2007 Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP - ju?j '1A By all G. Gale, Esquire v -a : 77 i--; ? r, t._ - ?. O'TTCCs "mil 1 16. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B.SAUERWINE FILE NO. 07-2784 Civil Term 217 Allendale Way Camp Hill, PA 17011 Plaintiff, VS. JOSEPH K. CHIARA 513 South 3rd Street Lemoyne, PA 17043 Defendant. RULE TO FILE A COMPLAINT AND NOW, this * day of _ GCJD _r , 2007, a Rule is entered upon the Plaintiff to file a Complaint within twenty (20) days after service of the Rule or suffer Judgment of Non Pros. By' i'l ou" P Prothonotary C6 Distribution List: Randall G. Gale, Esquire THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7648; fax: 717-237-7105 rgale@tthlaw.com Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES, P.C. 55 West High Street Elizabethtown, PA 17022 (717) 367-2800; fax: 717-367-9400 hhendersongpechtlaw.com " o C ? C7.) - n cr C-1 r`' cr ? ,fi PECHT & ASSOCIATES, PC Herbert P. Henderson, II, Esquire Pennsylvania I.D. No.: 56304 55 West High Street Elizabethtown, PA 17022 (717) 367-2800 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff vs. JOSEPH K. CHIARA 513 South 3`d Street Lemoyne, PA 17043 Defendant File No. 07-2784 Civil Action - JURY TRIAL DEMANDED NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone (717) 249-3166 PECHT & ASSOCIATES, PC By: r Herbert P. Henderson, II, Esquire Attorney for Plaintiff 55 West High Street Elizabethtown, PA 17022 Telephone: (717) 367-2800 Attorney I.D. #56304 PECHT & ASSOCIATES, PC Herbert P. Henderson, II, Esquire Pennsylvania I.D. No.: 56304 55 West High Street Elizabethtown, PA 17022 (717) 367-2800 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff vs. File No. 07-2784 Civil Action - JOSEPH K. CHIARA 513 South 3rd Street Lemoyne, PA 17043 Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff's herein are James H. Sauerwine and Arlene B. Sauerwine, husband and wife, currently residing at 217 Allendale Way, Camp Hill, Pennsylvania 17011. 2. Defendant herein is Joseph K. Chiara, an adult individual, currently residing at 513 South 3rd Street, Lemoyne, Pennsylvania 17043. 3. This cause of action arises from an automobile accident which occurred on or about May 9, 2005 on State Route 581 North at or near the off ramp of State Route 581 North just west of the US 83 South on ramp in Camp Hill, Cumberland County, Pennsylvania. STATEMENT OF FACTS 4. On May 9, 2005, Plaintiff James H. Sauerwine was on State Route 581 traveling from Mechanicsburg, Pennsylvania area toward Harrisburg, Pennsylvania in Cumberland County Pennsylvania. Plaintiff James H. Sauerwine was traveling in an easterly direction as he passed underneath what is commonly referred to as the 581/Rt. 15 underpass. 5. As Plaintiff James H. Sauerwine continued to travel on Route 581 toward Harrisburg, Pennsylvania, traffic on Route 581 came to an abrupt stop as he approached the intersection of Route 581 with US Route 83 South in or around New Cumberland, Pennsylvania. 6. At the same time and general location, a vehicle being operated by Defendant Joseph K. Chiara was traveling on the same roadway, in the same direction at approximately the same location. 7. Suddenly and without warning, Defendant collided violently with the rear portion of Plaintiff James H. Sauerwine's vehicle causing Plaintiff James H. Sauerwine to sustain serious personal injuries. COUNT ONE JAMES H. SAUERWINE AND ARLENE B. SAUERWINE VS. JOSEPH K. CHIARA 8. Paragraphs 1 through 6 are incorporated herein by reference as set forth at length. 9. Plaintiffs believe, and therefore aver that as a direct and proximate result of the negligence and the carelessness of the Defendant operating his motor vehicle at the same time and general location as aforesaid, that Plaintiff James H. Sauerwine suffered serious personal injuries, including specifically an injury to his neck which has resulted in the need for surgery. 10. Plaintiffs believe, and therefore aver that, again as a direct and proximate result of the negligence and carelessness of the Defendant that Plaintiff James H. Sauerwine: a. suffered serious, painful and permanent bodily injuries, great physical pain and mental anguish, severe and substantial emotional distress, and loss of capacity for the enjoyment of life; b. was, and will be required to undergo medical treatment and to incur medical costs and expenses in order to alleviate injuries, pain and suffering; C. was, is, and will be precluded from engaging in normal activities and pursuits, including a loss of his ability to earn money an actual earnings; and d. otherwise was hurt, injured, and caused to sustain financial losses. 11. Plaintiffs believe, and therefore aver that the above referenced collision was caused by the recklessness, carelessness and/or negligence of Defendant, for that, amongst other acts and omissions, Defendant: a. operated the motor vehicle at a high, dangerous and excessive rate of speed under the circumstances then and there existing; b. failed to reduce his speed to avoid a collision; C. failed to observe due care and precaution and maintain proper and adequate control of his motor vehicle; d. failed to operate his motor vehicle in such a manner as to bring the vehicle to stop completely within an assured clear distance ahead; C. failed to keep a proper lookout for other vehicles lawfully upon the roadway; f, failed to exercise reasonable care in the operation of his motor vehicle under the circumstances then and there existing. 12. All of the Plaintiff's losses were, are and will be due solely to and by reason of the reckless, carelessness and/or negligence of the Defendant, without any negligence or want of due care on the Plaintiffs' part contributing thereto. WHEREFORE, Plaintiffs respectfully requests judgment in their favor and against Defendant Joseph Chiara in an amount in excess of $35,000.00. COUNT TWO ARLENE B. SAUERWINE VS. JOSEPH CHIARA 13. Paragraphs 1 through 12 are incorporated herein by reference as set forth at length. 14. As a result of the carelessness and negligence of Defendant Joseph Chiara as aforesaid, Plaintiff Arlene B. Sauerwine has been deprived of companionship and otherwise suffered a loss of the quality of her relationship with Plaintiff James H. Sauerwine. 15. As a result of the carelessness and negligence of Defendant, Plaintiff Arlene B. Sauerwine has suffered a deprivation in some degree of the companionship, affection, sexual relations, and cooperation of her spouse, Plaintiff James H. Sauerwine, as a result of the injuries he suffered. WHEREFORE, Arlene B. Sauerwine respectfully requests judgment in her favor and against Defendant Joseph Chiara in an amount in excess of $35,000.00. Respectfully Submitted, PECHT & ASSOCIATES, PC By: tieroert r. tienaerson, 11, hsquire 55 West High Street Elizabethtown, PA 17022 (717) 367-2800 Attorney ID # 56304 VERIFICATION HERBERT P. HENDERSON, II5 ESQUIRE, being duly affirmed according to law deposes that he is the attorney for the Plaintiff, James H. Sauerwine in the within matter; that said Plaintiff cannot make the Verification to this Complaint because a Verification cannot be obtained at present, that he has made diligent inquiry of the Plaintiff and upon the information received believes the facts set forth to be true. Herbert P. Henderson, ?-? ?.:_a -_-? -1 ? ") ? ? ? r _ ?, -°:? _. ,?- r?,? •.. M1,?:f .• . Ate. I gym..., • -? Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B.SAUERWINE FILE NO. 07-2784 Civil Term 217 Allendale Way Civil Action - Camp Hill, PA 17011 Plaintiff, vs. JOSEPH K. CHIARA Jury Trial Demanded 113 Shetland Drive Hummelstown, PA 17036 Defendant. NOTICE TO PLEAD TO: Plaintiffs and Counsel You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. THOMAS, THOMAS & HAFER, LLP By Rall G. Gale, Esquire Attorney No. 26149 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7648; Fax: 717-237-7105 RGALE(&,,TTHLAW.COM DATE: January 2, 2008 Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B.SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff, vs. JOSEPH K. CHIARA 113 Shetland Drive Hummelstown, PA 17036 Defendant. FILE NO. 07-2784 CIVIL ACTION JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF JOSEPH K. CHIARA AND NOW, comes the Defendant Joseph K. Chiara and files this Answer and New Matter to the Complaint of Plaintiffs James H. Sauerwine and Arlene B. Sauerwine. 1. Denied. The averments of paragraph 1 of Plaintiffs' Complaint are neither admitted nor denied in that after reasonable investigation the Answering Defendant is without sufficient information to form a belief as to the truth of the averments and proof thereof is demanded. 2. Admitted in part and denied in part. It is admitted that Defendant Joseph K. Chiara is an adult individual. It is denied that he currently resides at 513 South Third Street, Lemoyne, Pennsylvania 17043. On the contrary, he currently resides at 113 Shetland Drive, Hummelstown, PA 17036. 3. Denied. The averments of paragraph 3 of Plaintiffs' Complaint are a conclusion of law to which no response is required. To the extent that a response may be deemed to be required the averments are denied and put in issue pursuant to Pa.R.Civ. 1029(e). 4-7. Admitted in part and denied in part. It is admitted that on May 9, 2005 Defendant Joseph K. Chiara was operating a vehicle east on State Route 581 and that his vehicle came in to contact with a vehicle operated by Plaintiff James. H. Sauerwine who was also operating a vehicle eastbound on State Route 581. The remaining averments of paragraph 4 through 7 of Plaintiffs' Complaint are denied and put in issue pursuant to Pa.R.Civ.P. 1029(e). COUNT ONE 8. The answering Defendant incorporates by reference his responses to paragraphs 1 through 7 of Plaintiffs' Complaint as if set forth at length herein. 9. Admitted in part and denied in part. It is admitted that Defendant operated his motor vehicle at the time and location as alleged. The remainder of the averments of paragraph 9 are denied and put in issue pursuant to Pa.R.Civ.P. 1029(e). 10 (a-d). Denied. The averments of paragraph 10 and its subparagraphs (a) through (d) are denied and put in issue pursuant to Pa.R.Civ.P. 1029(e). 11. Denied. The averments of paragraph 11 and its subparagraphs (a) through (f) are denied and put in issue pursuant to Pa.R.Civ.P. 1029(e). 12. Denied. The averments of paragraph 12 of Plaintiffs' Complaint are conclusions of law to which no response is required. To the extent a response may be 2 deemed to be required the averments are denied and put in issue pursuant to Pa.R.Civ.P. 1029(e). WHEREFORE, Joseph K. Chiara demands that Judgment be entered in his favor and against the Plaintiffs James H. Sauerwine and Arlene B. Sauerwine. COUNT TWO 13. The answering Defendant incorporates by reference his responses to paragraphs 1 through 12 of Plaintiffs' Complaint as if set forth at length herein. 14.-15. Denied. The averments of paragraphs 14 through 15 of the Plaintiffs' Complaint are conclusions of law to which no response is required. To the extent a response may be required the averments are denied and put in issue pursuant to Pa.R.Civ.P.1029(e). WHEREFORE, the Defendant Joseph K. Chiara demands that Judgment be entered in his favor and against the Plaintiffs Jaynes H. Sauerwine and Arlene B. Sauerwine. NEW MATTER 20. No acts or failures to act on the part of answering Defendant were a substantial factor or factual cause in bringing about the injuries or damages set forth in Plaintiffs' Complaint. 21. The Plaintiffs' claims are all subject to the provisions and limitations of the Pennsylvania Motor Vehicle Financial Responsibility Law. 22. The Plaintiffs' recoverable damages are or may be affected by their tort option election. 23. Plaintiffs' action is or may be time barred by the applicable two-year statute of limitation. WHEREFORE, the Defendant Joseph K. Chiara demands that Judgment be entered in his favor and against the Plaintiffs James H. Sauerwine and Arlene B. Sauerwine. THOMAS, THOMAS & HAFER, LLP By Ra13 nall G. Gale, Esquire Attorney No. 26149 305 North Front Street, 6 h Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7648; Fax: 717-237-7105 RGALE ,TTHLAW.COM DATE: January 2, 2008 4 VERIFICATION I, RANDALL G. GALE, ESQUIRE, have read the foregoing Answer and New Matter of Joseph K. Chiara and hereby affirm that it is true and correct to the best of my personal knowledge or information and belief. This Verification and statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to sworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S.§4904. RAND G. GALE, ESQUIRE Dated: January 2, 2008 556907.1 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE, Attorney for Defendant Joseph K. Chiara, do hereby certify that a copy of the Answer and New Matter was served upon the following by enclosing a true and correct copy in envelopes addressed as follows, postage prepaid, and depositing same in the United States Mail at Harrisburg, Pennsylvania, on the -.24 , 2008. of ld& Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP 13y Udn?all G. Gale, Esquire t? N t: ? ca t~ c ? -n v ? rr-r CD -G Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B.SAUERWINE FILE NO. 07-2784 Civil Term 217 Allendale Way Civil Action - Camp Hill, PA 17011 Plaintiff, vs. JOSEPH K. CHIARA Jury Trial Demanded 113 Shetland Drive Hummelstown, PA 17036 Defendant. PRAECIPE TO SUBSTITUTE VERIFICATION TO: The Prothonotary: Please substitute the attached original verification of Joseph K. Chiara on the Answer and New Matter of Joseph K. Chiara in place of the previous verification signed by counsel. THOMAS, THOMAS & HAFER, LLP By AandfA7G--. Gale, Esquire Attorney No. 26149 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7648; Fax: 717-237-7105 RGALEgTTHLAW.COM DATE: January 11, 2008 VERIFICATION I, Joseph K. Chiara, have read the foregoing Answer and New Matter of Joseph K. Chiara and hereby affirm that it is true and correct to the best of my personal knowledge or information and belief. This Verification and statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to sworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S.§4904. Dated: 556928.1 Joseph K. hiara,, Certificate of Service I, Randall G. Gale, Attorney for Defendant, Joseph K. Chiara do hereby certify that I served a copy of the foregoing document upon the following this I Ith day of January, 2008, by placing a true and correct copy in the U.S. mail, first-class, postage pre-paid, addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP By: Randall G. Gale, Esquire 556856.2 c'? .....? ? ?-a t' T ? . .,.,,. crt ; ?-- .? , e:_? ',' - ? . i°? ? r.- ? _1 ??J = .V ?? + ? PECHT & ASSOCIATES, PC Herbert P. Henderson, II, Esquire Pennsylvania I.D. No.: 56304 55 West High Street Elizabethtown, PA 17022 (717) 367-2800 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff vs. JOSEPH K. CHIARA 513 South 3rd Street Lemoyne, PA 17043 File No. 07-2784 Civil Action - JURY TRIAL DEMANDED Defendant RESPONSE TO NEW MATTER 20. Denied. The averments in paragraph 20 of Defendant's New Matter are denied. Strict proof otherwise is demanded at the time of trial. 21. The averments of paragraph 21 of Defendant's New Matter are conclusions of law to which no response is required. To the extent an answer may be required, the averments are denied and strict proof otherwise is demanded at the time of trial. 22. Admitted to the extent of Plaintiffs' tort option speaks for itself. 23. Denied. The averments in paragraph 23 of Defendant's New Matter are denied. To the contrary, Plaintiffs' claim is not barred by any statute of limitation. Strict proof otherwise is demanded at the time of trial. Respectfully Submitted, PECHT & ASSOCIATES, PC By: Herbert P. Henders ,11, Esquire 55 West High Street Elizabethtown, PA 17022 (717) 367-2800 Attorney ID # 56304 VERIFICATION I have read the foregoing and hereby affirm that to the questions to which I provided answers are true and correct to the best of my knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to the unworn falsification to authorities. J s H. Saue e VERIFICATION I have read the foregoing and hereby affirm that to the questions to which I provided answers are true and correct to the best of my knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to the unworn falsification to authorities. Arlene B. Sauerwine ??; ? ;? ,.-?, r-, s:::7 -i1 !_... ? ?? ??. : ,^ .1 T;t? E"`.7 .. ;' .,? ?. --C Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, FILE NO. 07-2784 Civil Term Plaintiffs vs. JOSEPH K. CHIARA Defendant. CERTIFICATE PREREQUISITE TO SERVICE OF'SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoenas with a copy of the Subpoenas attached thereto was mailed to Plaintiffs' counsel on 7/8/08; (2) a copy of the Notice of Intent, including the proposed Subpoenas, is attached to this certificate; (3) Plaintiffs' counsel has indicated in a letter of July 18, 2008 that he has no objection to the proposed Subpoenas and is willing to waive the remainder of the 20-day notice period in order to expedite receipt of the records; and (4) the Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent to serve the Subpoenas. THOMA,,%-THOMAS & HAFER, LLP RAIND L G. GALE, ESQUIRE I.D. 149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: 1. „???F Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, FILE NO. 07-2784 Civil Term Plaintiffs vs. JOSEPH K. CHIARA Defendant. 'NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RRU1E 4009.21 TO: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 Defendant intends to serve subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. THOMA?T-HOMAS & HAFER, LLP RA'b"LL G. GALE, ESQUIRE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: 7- if -0 K IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Lancaster Neuroscience & Spine Associates 1671 Crooked Oak Drive, Lancaster, PA 17601 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records reports treatment notes, correspondence, diagnostic studies, radiology films of the cervical spine, testing results, bills, insurance forms, medication/prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form relating to the care and treatment of James Sauerwine d/o/b: 12/7/49 SSN 201-40-1242. This request is for updated records only from January 2008 to present at: Thomas Thomas & Hafer LLP 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, VS. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Lancaster General Hospital, 555 North Duke Street, Lancaster, PA 17604-3555 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A copy of all ER reports discharge summaries history and physicals operative reports and consultation reports including any and all such items that may be stored in a computer database or otherwise in electronic form relating to the care and treatment of James Sauerwine, DOB: 12/7/49 SSN 201-40-1242. Please also include a copy of your complete billing records from 2000 - present. at Thomas Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburg PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Lancaster General Hospital Dept. of Radiology and Diagnostic Imaging, 555 North Duke Street, Lancaster, PA 17604-3555 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the x-ray films including CT scans and NM films in your possession of the cervical spine of James Sauerwine, DOB: 1217/49, SSN 201-40-1242 as well as complete copies of the radiology reports, handwritten notes, orders, correspondence, memoranda, billing records (including any records stored in a computer database or otherwise in electronic form) relating to all radiology studies performed on Mr. Sauerwine. at: Thomas Thomas & Hafer LLP 305 N. Front St. P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: BY THE COURT: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, VS. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Walter C. Peppelman, Jr., D.O./Pennsylvania Spine Institute, 805 Sir Thomas Court, Harrisburg, PA 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: AU and all medical records reports, treatment notes, correspondence, diagnostic studies, radiology films of the cervical spine, testing results, bills, insurance forms, medication/prescription information including any and all such items that may be stored in a commuter database or otherwise in electronic form. relating to the care and treatment of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242. at: Thomas Thomas & Hafer. LLP 305 N Front St P.O. Box 999, Harrisburg PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, VS. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records HealthSouth Hospitals of Mechanicsburg, 175 Lancaster Boulevard, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all inpatient and outpatient medical records reports treatment notes, physical therapy records special procedures clinic records pain management clinic records correspondence diagnostic studies radiology films of the cervical spine, testing results, bills, insurance forms, medication/prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form relating to the care and treatment of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242. at: Thomas Thomas & Hafer LLP 305 N Front St P.O. Boa 999, Harrisburg PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Boa 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Magnetic Imaging Center, 4665 Trindle Road, Mechanicsburg, PA 17050 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete conies of the x-ray films including CT scans and MRI films in your possession of the cervical spine of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242 as well as complete conies of all radiology reports, handwritten notes, orders, correspondence, memoranda, billing records (including any records stored in a computer database or otherwise in electronic form) relating to all radiology studies performed on Mr. Sauerwine. at Thomas Thomas & Hafer. LLP 305 N Front St P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, VS. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Susquehanna Valley Pain Management, P.C., 825 Sir Thomas Court, Suite B, Harrisburg, PA 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records reports treatment notes, physical therapy records, special procedures clinic records pain management clinic records correspondence. diagnostic studies, radiology films of the cervical spine, testing results, bills, insurance forms, medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242. at: Thomas Thomas & Hafer, LLP 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108-0999. You may deliver or mail legible copies of th6466uments'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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Smith Radiology Inc 1515 Bridge Street New Cumberland. PA 17070 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of all cervical spine x-ray films including CT scans and MRI films in your possession of the cervical spine of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242 as well as complete conies of all radiology reports, handwritten notes, orders, correspondence, memoranda, billing records (including any records stored in a computer database or otherwise in electronic form) relating to all radiology studies performed on Mr. Sauerwine. at: Thomas Thomas & Hafer LLP 305 N. Front St. P.O. Box 999. Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT 1D#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records CVS Pharmacy, 1120 Carlisle Road Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A complete copy of your entire file on James Sauerwine, DOB: 12/7/49, SSN 201-40-1242, relating to the history of prescriptions filled for James Sauerwine for the period of time from 2000 - rp esent as well as Pharmacist 's Statement, Customer History Report, telephone messages, prescriptions, telephone scripts, prescription log/history, order forms, faxes, insurance log/history, and any and all billing records or payment ledger for James Sauerwine during the same period of time (including any records stored in a computer database or otherwise in electronic form). at: Thomas Thomas & Hafer. LLP 305 N Front St. P.O. Box 999, Harrisburg, PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliane,e,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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, VS. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Holy Spirit Hospital 503 N. 2151 Street Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records for inpatient, outpatient, ER or clinic care including reports treatment notes correspondence diagnostic studies radiology films testing results bills insurance forms medication/prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine DOB: 12/7/49, SSN 201-40-1242 at: Thomas Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburg PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Keystone Spine Center, 3552 Gettysburg Road. Camp Hill. PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes, correspondence, diagnostic studies, radiology films of the cervical spine, testing results, bills, insurance forms, medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242. at Thomas Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburc PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records PRISM/William A Rolle Jr. M.D., 450 Powers Avenue Rear, Harrisburg, PA 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes, correspondence, diagnostic studies, radiology films of the cervical spine, testing results, bills, insurance forms, medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242. at Thomas Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: BY THE COURT: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF ZERVICE 1, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP R ND G. GALE, ESQUIRE Date: l 607459.1 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP /19 / 44?d 11'!A6 RA "L G. GALE, E QUIRE Date: -7 - ;- a -?-f C) I t ?t _ ;1 ?Tl ? y Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant. FILE NO. 07-2784 Civil Term CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed to Plaintiffs' counsel on 8/4/08; (2) a copy of the Notice of Intent, including the proposed Subpoena, is attached to this certificate; (3) Plaintiffs' counsel has indicated in a letter of August 12, 2008 that he has no objection to the proposed Subpoena and is willing to waive the remainder of the 20-day notice period in order to expedite receipt of the records; 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. THOMAS & HAFER, LLP I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: CI " 15-68' Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant FILE NO. 07-2784 Civil Term NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR .DISCOVERY PURSUANT TO RULE 4009.21 TO: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 Defendant intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. THOMAS, THOMAS & HAFER, LLP RANPALL G. GALE, ESQUIRE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: J J ?/_ o g IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Argires, Becker & Westphal 2150 Harrisburg Pike, Suite 200, Lancaster, PA 17601 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes, correspondence, diagnostic studies, radioloF-,y films of the cervical spine, testing results, bills, insurance forms, medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, d/o/b: 12/7/49, SSN 201-40-1242. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St.. P.O. Box 999. Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE 1, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP RA G. GALE, ESQUIRE Date: ?- V-0 614552.1 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire Wayne M. Pecht, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP ALL G. GALE, SQUIRE Date: 5? - a-- ee R±? ?'? !? 4 ?, ? ? / ? ? 1z/ ? ?? i mow: -} `r s. .,.,? ? r ?'r ? ? ?t C,3 - K. Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant. FILE NO. 07-2784 Civil Term CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE x.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoenas with a copy of the Subpoena attached thereto was mailed to Plaintiffs' counsel on February 18, 2009; (2) a copy of the Notice of Intent, including the proposed Subpoenas, is attached to this certificate; (3) Plaintiffs' counsel has indicated via email of February 19, 2009 that he has no objection to the proposed Subpoenas and is willing to waive the remainder of the 20-day notice period in order to expedite receipt of the records; and (4) the Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent to serve the Subpoenas. THOMAS, THOMAS & HAFER, LLP i RANDALL G. GALE, E SOME I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: ??. 3 Randall G. Gate, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, FILE NO. 07-2784 Civil Term Plaintiffs vs. JOSEPH K. CHIARA Defendant. NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009,21 TO: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 Defendant intends to serve subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. THOMAS, THOMAS & HAFER, LLP 461149RU. GAL QUIRE 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: rf le Q 9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Argires, Becker & Westphal 2150 Harrisburg Pike, Suite 200, Lancaster, PA 17601 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records reports treatment notes correspondence, diagnostic studies, radiology films of the cervical spine testing results bills insurance forms, medication/prescription information including _any and all such items that may be stored in a computer database or otherwise in electronic form relating to the care and treatment of James Sauerwine d/o/b• 12/7/49 SSN 201-40-1242 from August 1, 2008 - present. at Thomas Thomas & Hafer LLP 305 N Front St. P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Red Cedar Family Practice/James Blacksmith, D.O. 689 Yorktown Road, Lewisberry, PA 17339 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes, correMondence, diagnostic studies radiology films, testing results, bills, insurance forms, medication/prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, d/o/b: 12/7/49 SSN 201- 40-1242 from January 2008 - present at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisbure PA 17108-0999 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Quantum Imaging & Therapeutic Associates Inc. 405 St. John's -Church Road Suite 102, Camp Hill PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the x-ray films including CT scans and NM films in your possession of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242 as well as complete copies of all radiology reports, handwritten notes, orders, correspondence, memoranda, billing records (including any records stored in a computer database or otherwise in electronic form) relating to all radiology studies performed on Mr. Sauerwine. at: Thomas Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburg PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF `SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP RA D L G. GALE, ESQUIRE Date: ? - I k--S 614552.2 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP RAN L G. ALE, -EMOUIRE Date: 3- 3,, O l c. 33 co Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant FILE NO. 07-2784 Civil Term CERTIFICATE PRERE rrE TO ZEfW1CE OF P mAS PURSUANT TO RULE 4!.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoenas with a copy of the Subpoena attached thereto was mailed to Plaintiffs' counsel on March 11, 2009; (2) a copy of the Notice of Intent, including the proposed Subpoenas, is attached to this certificate; (3) Plaintiffs' counsel has indicated via letter of March 23, 2009 that he has no objection to the proposed Subpoenas and is willing to waive the remainder of the 20-day notice period in order to expedite receipt of the records; and (4) the Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent to serve the Subpoenas. THOM THOMAS & HAFER, LLP r R LL G. GALE, 19-SOTAIkE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 Date: ATTORNEY FOR DEFENDANT U Randall G. Gale; Esquire Attorney # 26149 THOMAS. THOMAS & HAFER, LLP P.O. Box, 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, FILE NO. 07-2784 Civil Term Plaintiffs vs. JOSEPH K. CHIARA Defendant. NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO -RULE 4009.21 TO: I-Jerhert P. Henderson, Ii, Esgquire PECHT & ASSOCIATES 55 West. High Street Elizabethtown, PA 17022 Defendant intends to serve subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. THOMAS, THOMAS & HAFER, LLP RAIUALL G. GALE, ESQUIRE LD. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: J A4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE vs. JOSEPH K. CHIARA Plaintiff, Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Tristan Associates 4518 Union Deposit Road, Harrisburg, PA 17111 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records. reports treatment notes correspondence diagnostic studies radioloay films or CDs of films, testinp, results, bills insurance forms medication/prescription information. including any and all such items that may be stored in a computer database or otherwise in electronic form. relatiny- to the care and treatment of James Sauerwine d/o/b• 12/7/49. SSN 201-40-1242 from September 2007- present at: Thomas. Thomas & Hafer. LLP, 305 N. Front St. P.O. Boa 999 Harrisburg PA 17108-0999 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: Randall G. Gale, Esquire ADDRESS: P.O. Boa 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk. Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff. vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Orthopedic Institute of Pennsylvania 3399 Trindle Road, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: .Anv and all medical records reports treatment notes correspondence diagnostic studies radiology films or digital copies on CD, testing results. bills. insurance forms niedicatioii/prescription information. including any and all such items 'chat may be stoned in a computer database or otherwise in electronic form. relating to the care and treatment of James Sauerwine. d/o/b: 12/7/49. SSN 201-40-1242 from November 2007 - present at: Thomas. Thomas & Hafer, LLP, 305 N. Front St.. P.O. Boa 999. Harrisburg. PA 17108-0999 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 b); 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street. Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff. VS. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records. Susquehanna Valley Pain Management. P.C./Harrisburg, Interventional Pain Management Center, 825 Sir Thomas Court, Suite B, Harrisburg, PA 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Anv and all medical records reports treatment notes physical therapy records special procedures clinic records, pain management clinic records. correspondence. diagnostic studies radiology films. testing, results, bills. insurance forms, medication/prescription information including, any and all such items that may be stored in a computer database or otherwise in electronic form. relating, to the care and treatment of James Sauerwine, DOB: 12/7/49 SSN 201- 40-1242 from July 2008 - present. at: Thomas. Thomas & Hafer. LLP, 305 N. Front St.. P.O. Box 999, Harrisburg,. PA 17108-0999 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 1 7 1 08-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Deputy Prothonotary/Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE vs. JOSEPH K. CHIARA Plaintiff. Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, HealthSouth Hospitals of Mechanicsburg. 175 Lancaster Boulevard Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all inpatient and outpatient medical records. reports. treatment notes physical therapy records. special procedures clinic records. pain management clinic records correspondence diagnostic studies, radiology filins of the cervical spine. testing results bills insurance forms medication/prescription information, including any and all such items that may be stored in a computer database or otherwise in electronic form. relating to the care and treatment of James Sauerwine. DOB: 12/7/49. SSN 201-40-1242 from Au`ust 2008 -present. at: Thomas. Thomas R. Hafer. LLP, 305 N. Front St.. P.O. Boa 999. Harrisburg PA 17108-0999 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg. PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWI TE and ARLENE B. SAUERNWINE Plaintiff. VS. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Drayer Physical Therapy Institute. 5108 E. Trindle Road Suite 200 Mechanicsburg, PA 17050 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, treatment notes, correspondence, diagnostic studies, radiology films of the spine, testing results, physical therapy records, bills, insurance forms, medicat oaa/prescrip ion info rir,adon, including any and all such items that ;ueay be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine, DOB: 12/7/49, SSN 201-40-1242. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Boa 999. Harrisburg. PA 17108-0999. 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 part), 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: Randall G. Gale, Esquire ADDRESS: P.O. Boa 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk. Civil Division Deputy CERTIFICATE OF SERVICE 1, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, It, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP 1 rRA ALL G. GALE, ESQUIRE Date: ??6 ?? 614552.3 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP RAN L G. GAL 0UIR Date: 1--3 &,- 61 RLF -; -? E OF THE i ",h!^TARY 2009 AR 31 All 11: 5 4 ; Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant. FILE NO. 07-2784 Civil Term CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed to Plaintiffs' counsel on May 14, 2009 which is 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. MAS & HAFER, LLP Date: 6-- k"- 4? RAN94L-L G. GALE, ESQUIRE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. FILE NO. 07-2784 Civil Term JOSEPH K. CHIARA Defendant. NOTICE OF INTENT TO SERVE A'SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT`TO RULE 4009.21 TO: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 Defendant intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. THOMAS ZHOMAS & HAFER, LLP J RA D L G. GAL , ESQUIRE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: ?-r( q -0 q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. NO. 07-2784 CIVIL ACTION - LAW JOSEPH K. CHIARA Defendant. JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records York Hospital, 1001 S. Geor e Street York PA 17405-7187 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records reports treatment notes correspondence diac'nostic studies radiology films or CDs of films testing results bills insurance forms, medication/prescription information, including anand all such items that ma be stored in a computer database or otherwise in electronic form relating to the care and treatment of James Sauerwine d/o/b: 12/7/49. S SN 201-40-1242 from 2000 to present at Thomas Thomas & Hafer LLP 305 N. Front St. P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy 4. 1 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP 7 RA D L G. GALE, ESQUI Date: 5-1Z11-'!9 C 614552.5 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP RA A--2 LL . GALE, ESQUIRE Date: d- ke FILEDXD; SCE OF THE Pr's M",`NI OTAPY 2009 JUN -9 PM 12, 41 PENN`aY LV "vA Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA ATTORNEYS FOR DEFENDANT FILE NO. 07-2784 Civil Term CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed to Plaintiffs' counsel on May 13, 2009 which is 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. THOMAS, THOMAS $ HAFER, LLP Rfi(ND4kf G. GALE, ESQUIRE I.D. 149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 Date: &,?t? ATTORNEY FOR DEFENDANT Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant FILE NO. 07-2784 Civil Term NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERYPURSUANT TO RULE 4009.21 TO: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 Defendant intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. THOMAS, THOMAS & HAFER, LLP RA DAL G. ALE, E I.D. 149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: 3 AD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. JOSEPH K. CHIARA Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records Nationwide Auto Claims P. O. Box 69600, Harrisburg, PA 17106-9600 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A complete copy of the first-party claim file without limitation regardin your insured James H Sauerwine. DOB 12/7/49 (Claim Number 5837PE01844611300851) arisma out of a motor vehicle accident on or about November 30 2008, including, but not limited to: application for benefits physician 's statement, s wage verifications policy declarations page(s) showing coverage or tort option elections summaries of payments made. first party benefit payout logs and any information regarding any liens asserted by any entities medical records and reports bills Peer Review reports IME reports and correspondence and all other documents and things without limitation at Thomas Thomas & Hafer LLP 305 N. Front St. P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999,305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP t RAN G. GALE, ESQUIRE Date:- "1 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP RAN A G. GALE, ESQUIRE Date: k, ;-kfs DF ty?tEO..?,, -?,?, ? p?,,,.. %,,,.,?' r.?.?,?rry,,? ?p?? ??? _ _ ? T??y` ?U,??,,., ? '°? I?- 4 ? ?:;, f"'1v ?. ???Wt?,S YC t? ?`'??'i Y'?y? ?? Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. JOSEPH K. CHIARA Defendant. FILE NO. 07-2784 Civil Term CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that (1) a Notice of Intent to Serve the Subpoenas with a copy of the Subpoenas attached thereto was mailed to Plaintiffs' counsel on June 29, 2009; (2) a copy of the Notice of Intent, including the proposed Subpoenas, is attached to this certificate; (3) Attorney Henderson has indicated via email of July 9, 2009 that he has no objection to the proposed Subpoenas and is willing to waive the remainder of the 20-day notice; and (4) the Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent to serve the Subpoenas. THOM , THOMAS & HAFER, LLP R N L G. G , SQUIRE 1. .2614159 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 l 3 ?? ATTORNEY FOR DEFENDANT Date: Randall G. Gale, Esquire Attorney # 26149 THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108-0999 ATTORNEYS FOR DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE and ARLENE B. SAUERWINE, Plaintiffs vs. FILE NO. 07-2784 Civil Term JOSEPH K. CHIARA Defendant. NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 Defendant intends to serve subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. THOMAS, THOMAS & HAFER, LLP 4(61 7L RAN A . GAL -E, ES IRE I.D. 26149 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7648 ATTORNEY FOR DEFENDANT Date: ?-;q- C ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE vs. JOSEPH K. CHIARA Plaintiff, Defendant. NO. 07-2784 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Olivetti Chiropractic, 856 Century Drive, Suite C, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records reports treatment notes correspondence diagnostic studies radiology films, testing results bills insurance forms medication/ prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form, relating to the care and treatment of James Sauerwine d/o/b 12/7/49 SSN 201 40-1242 at. Thomas Thomas & Hafer, LLP. 305 N. Front St. P.O. Box 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: Sea] of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES H. SAUERWINE and ARLENE B. SAUERWINE Plaintiff, vs. NO. 07-2784 CIVIL ACTION - LAW JOSEPH K. CHIARA Defendant. JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, John Pikulin, D.C., 221 Bridge Street, New Cumberland, PA 17070 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Anv and all medical records, reports treatment notes correspondence diagnostic studies radiology films. testing results bills insurance forms medication/prescription information including any and all such items that may be stored in a computer database or otherwise in electronic form. relating to the care and treatment of James Sauerwine d/o/b• 12/7/49 SSN 201 40-1242 at: Thomas Thomas & Hafer LLP 305 N. Front St. P.O. Boa 999, Harrisburg, PA 17108-0999. 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: Randall G. Gale, Esquire ADDRESS: P.O. Box 999, 305 N. Front Street, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7648 SUPREME COURT ID#: 26149 ATTORNEY FOR: Defendant DATE: BY THE COURT: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP SRAN L G. 4QUIRE , Date: f? 614552.6 CERTIFICATE OF SERVICE I, RANDALL G. GALE, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Herbert P. Henderson, II, Esquire PECHT & ASSOCIATES 55 West High Street Elizabethtown, PA 17022 THOMAS, THOMAS & HAFER, LLP i` RA L G. AL U R 18 Date: /-/ 314 ? ?? ?;?,?Y ?? Tu._ ?v -,-,, ,,, ._. ?- PECHT & ASSOCIATES, PC . Herbert P. Henderson, II, Esquire CQ 1 Q A P PA ID No.: 56304 AM 11: 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055 G; f '?FYt 7 (717) 691-9808 { IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES H. SAUERWINE, and ARLENE B. SAUERWINE 217 Allendale Way Camp Hill, PA 17011 Plaintiff VS. JOSEPH K. CHIARA 113 Shetland Drive Hummelstown, PA 17036 Defendant FILE NO. 07-2784 CIVIL ACTION JURY TRIAL DEMANDED PRAECIPE TO SETTLE, SATISFY and DISCONTINUE To: David Buell, Prothonotary Kindly mark the docket with regard to the above-referenced matter, Settled, Satisfied and Discontinued. Respectfully submitted, PECHT & ASSOCIATES, PC April 28, 2010 Herbert P. Henderson, II, Esquire PA ID No.: 56304 Attorney for Plaintiff 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055 (717) 691-9808