HomeMy WebLinkAbout07-3244IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA c
No. 3 a-yS/ 20 Q ` Clv ?ex,*,
Civil Action - (X) Law
() Equity
HELEN BRIDGES
2238 KENSINGTON STREET
HARRISBURG, PA 17104
Plaintiff(s) &
Addresses
JURY TRIAL DEMANDED
Defendant(s) &
Addresses
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue writ of summons in the above-captioned action.
X Writ of Summons shall be issued and forwarded to ( )Attorney (X)Sheriff
JOSEPH J. DIXON, ESQUIRE
126 STATE STREET Sign of Attorney
HARRISBURG, PA 17101
(717) 236-8515 Supreme Court ID No.28290
Names/Address/Telephone No. Of
Attorney Date:
WRIT OF SUMMONS
TO THE ABOVE-NAMED DEFENDANT(S)-
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION
AGAINST YOU.
s ? ? d
Prothonotary j
Date: `j1I ZS' 1 by Q,uc?a dl?4al
Deputy
HIGH ASSOCIATES, LTD.
5000 RITTER ROAD
•MECHANICSBURG, PA 17055
VS.
( ) Check here if reverse is issued for additional information.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-03244 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BRIDGES HELEN
VS
HIGH ASSOCIATES LTD
ROBERT BITNER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
HIGH ASSOCIATES LTD the
DEFENDANT , at 1450:00 HOURS, on the 1st day of June 2007
at 5000 RITTER ROAD
MECHANICSBURG, PA 17055 by handing to
DERRY YOUNG, ADULT IN CHARGE
a true and attested copy of WRIT OF SUMMONS together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 12.48
Postage .58
Surcharge 10.00
00
G11 #'0 7 ?., . 0 6
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
06/04/2007
JOSEPH DIXON
By :
Deputy Sheriff
A. D.
,If
POST & SCHELL, P.C.
BY: PAUL W. GREGO
I.D. #:39701
1857 WILLIAM PENN WAY
P.O. BOX 10248
LANCASTER, PA 17605-0248
717-291-4532
HELEN BRIDGES
Plaintiff,
V.
HIGH ASSOCIATES, LTD.
Defendant.
ATTORNEYS FOR DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 3244-2007 CIVIL TERM
JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of Defendant, High Associates, Ltd., in the above-
captioned matter. Defendant demands a Jury Trial of Twelve Jurors.
POST & SCHELL, P.C.
r
iBy: ('
x, P664x
Paul W. Grego
Attorney for Defendant
High Associates, Ltd.
CERTIFICATE OF SERVICE
I, Sandra Morales, an employee of the law offices of Post & Schell, P.C., do hereby
certify that on the date set forth below, I did serve a true and correct copy of the foregoing
document upon the following person(s) at the following address(es) by sending same in the
United States mail, first-class, postage prepaid:
Joseph J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
SANDRA MORALES
DATE: r Z g d 7
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POST & SCHELL, P.C.
BY: PAUL W. GREGO
I.D. #:39701
1857 WILLIAM PENN WAY
P.O. BOX 10248
LANCASTER, PA 17605-0248
717-291-4532
HELEN BRIDGES
Plaintiff,
V.
HIGH ASSOCIATES, LTD.
Defendant.
ATTORNEYS FOR DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 3244-2007 CIVIL TERM
JURY TRIAL DEMANDED
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please enter a Rule upon Plaintiff to file a Complaint within twenty (20) days hereof or
suffer the entry of a Judgment of Non Pros.
POST & SCHELL, P.C.
f
By.
Paul W. Grego
Attorney for Defendant
High Associates, Ltd.
RULE TO FILE COMPLAINT
?T
AND NOW, this je day of v , 2008, a Rule is hereby
granted upon Plaintiff to file a Complaint herein within twenty (20) days after service hereof or
suffer entry of Judgment of Non Pros.
Pr onotary
CERTIFICATE OF SERVICE
I, Sandra Morales, an employee of the law offices of Post & Schell, P.C., do hereby
certify that on the date set forth below, I did serve a true and correct copy of the foregoing
document upon the following person(s) at the following address(es) by sending same in the
United States mail, first-class, postage prepaid:
Joseph J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
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SANDRA MORALES
DATE: ;! /41099
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HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 3244 2007 CIVIL TERM
V.
HIGH ASSOCIATES,
CIVIL ACTION - LAW
Defendants .
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set for 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 LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
NOTICA
LE RAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de
estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en
persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las
demandas en contra de su persona. Sea avisado gue si usted no se defiende, la corte tomara
medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualguier
gueja o alivio gue es pedido en la peticion de demanda. Usted puede perder dinero o sus
propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
By:
Joseph J. Dixon, Esquire
Attorney ID No. 28290
126 State Street
Harrisburg, PA 17101
(717) 236-8515
Attorney for the Plaintiff
HELEN BRIDGES,
Plaintiff
v
HIGH ASSOCIATES, LTD.
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 3244 2007 CIVIL TERM
CIVIL ACTION-LAW
COMPLAINT
AND NOW, this 8t' day of February 8, 2008, the Plaintiff Helen Bridges by and
through her attorney, Joseph J. Dixon, Esquire who respectfully avers as follows:
1. The Plaintiff is Helen Bridges, an adult individual who resides at 223
Kensington Street, Harrisburg, Dauphin County, Pennsylvania 17104.
2. The Defendant is High Associates Limited, a Pennsylvania business
organization whose principal place of business is 5000 Ritter Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. At all times material hereto, the Defendant High Associates Limited
owned a building located at 5073 Ritter Road, Mechanicsburg,
Pennsylvania 17055.
4. At all times material hereto, the Plaintiff, Helen Bridges was an employee
of Delta Dental Corporation. Delta Dental Corporation rented the building
owned by the Defendant at 5073 Ritter Road, Mechanicsburg,
Cumberland County, Pennsylvania.
5. On or about February 5, 2005 at approximately 7:50 a.m., the Plaintiff
parked her car in a parking lot adjacent to her place of employment at
5073 Ritter Road, Mechanicsburg, Pennsylvania 17055.
6. The Plaintiff was advised to park at this parking lot by her employer, Delta
Dental Corporation and the Defendant, High Associates.
7. At said time and place, the Plaintiff began walking from her car towards
the entrance of the building located at 5073 Ritter Road, Mechanicsburg,
Pennsylvania.
8. At said time and place, the Plaintiff stepped into a pothole in the parking
lot twisting her back and causing her to fall.
9. The injuries sustained by the Plaintiff were caused by the negligence and
carelessness of the Defendant, High Associates Limited which consists of
the following:
(a) Improper maintenance of a parking lot.
(b) Failure to properly fix potholes in a parking lot.
(c) Failure to fix a hazardous condition in the parking lot after having
notice of the problems from prior falls.
(d) Failure to keep a parking lot even while people are walking from
their cars to the commercial building to walk safely to the
commercial building.
10. At all times material hereto, the actions and conduct of the Plaintiff did not
in anyway contribute to the injuries sustained by the Plaintiff.
11. As a result of the fall sustained by the Plaintiff, she suffered severe
personal injuries. These injuries include by are not limited to:
lumbosacral strain sprain, shoulder sprain strain, cervical sprain
strain, aggravation of cervical degenerative disease, herniated disc at the
L-4 L-5 level, herniated disc at the L-5 S-1 level, lumbosacral sprain
strain, aggravation of degenerative joint disease in the lumbar and
cervical spine, myofascial pain syndrome of the lumbar and cervical spine
lumbar segmental dysfunction, lumbar IVD displacement w/o
myelopathy, pelvic segmental, sacroiliac segment dysfunction,
abnormality of gait and lumbalgia.
12. As a sole and proximate result of the fall, the Plaintiff has incurred various
medical expenses and in the future will incur various medical expenses
and miscellaneous expenses. The total amount of which is unascertained at
this time.
13. As a sole and proximate result of the fall, the Plaintiff has suffered from a
loss of income and wages from work. The total amount of this loss is
unascertained at this time.
14. As a sole and proximate result of the fall, the Plaintiff has been advised
and therefore avers that she will have permanent residual physical
problems.
15. As a sole and proximate result of the fall, the Plaintiff has undergone in
the past great pain and suffering and will in the future will undergo great
pain and suffering.
16. As a sole and proximate result of the fall, the Plaintiff has had to severely
limit her activities of daily living.
WHEREFORE, the Plaintiff prays this Honorable Court enter judgment against
the Defendant in the amount less than Fifty Thousand Dollars ($50,000.00), an amount
requiring compulsory arbitration.
Respectfully submitted,
By:
Dixon, Esquire
Attorney ID No. 28290
126 State Street
Harrisburg, PA 17101
(717) 236-8515
Dated: :2z ?I ? q Attorney for the Plaintiff
VERIFICATION
1l ,are true and
I verify that the statements made in this 4/ /a/
correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S.
§4904, relating to unworn falsification to authorities.
Dated:
CERTIFICATE OF SERVICE
AND NOW, this 80' day of February, 2008, I, Joseph J. Dixon, Esquire, hereby certify
that I have served a true and correct copy of the foregoing document this day by depositing the
same the same in the United States Mail, first class, postage prepaid, in the Post Office at
Harrisburg, Pennsylvania, addressed to:
JOHN C. DEVINE, ESQUIRE
POST & SCHELL
1857 WILLIAM PENN WAY
P.O. BOX 10248
LANCASTER, PA 17605-0248
By:
Jo J. Dixon, Esquire
Attorney ID No. 28290
126 State Street
Harrisburg, PA 17101
(717)236-8515
Attorney for Plaintiff
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HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 3244 2007 CIVIL TERM
V.
HIGH ASSOCIATES,
CIVIL ACTION - LAW
Defendants .
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this Complaint
and Notice are served by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set for 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 LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
NOTICA
LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de
estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir
de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en
persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las
demandas en contra de su persona. Sea avisado gue si usted no se defiende, la corte tomara
medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualguier
gueja o alivio gue es pedido en la petition de demanda. Usted puede perder dinero o sus
propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
By:?-°
Jos J. Dixon, Esquire
Attorney ID No. 28290
126 State Street
Harrisburg, PA 17101
(717) 236-8515
Attorney for the Plaintiff
HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 3244 2007 CIVIL TERM
v
CIVIL ACTION-LAW
HIGH ASSOCIATES, LTD.,
Defendants
AMENDED COMPLAINT
AND NOW, this 24a` day of March, 2008, the Plaintiff Helen Bridges by and
through her attorney, Joseph J. Dixon, Esquire who respectfully avers as follows:
1. The Plaintiff is Helen Bridges, an adult individual who resides at 223
Kensington Street, Harrisburg, Dauphin County, Pennsylvania 17104.
2. The Defendant is High Associates Limited, a Pennsylvania business
organization whose principal place of business is 5000 Ritter Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. At all times material hereto, the Defendant High Associates Limited
owned a building located at 5073 Ritter Road, Mechanicsburg,
Pennsylvania 17055.
4. At all times material hereto, the Plaintiff, Helen Bridges was an employee
of Delta Dental Corporation. Delta Dental Corporation rented the building
owned by the Defendant at 5073 Ritter Road, Mechanicsburg,
Cumberland County, Pennsylvania.
5. On or about June 2, 2005 at approximately 7:50 a.m., the Plaintiff
parked her car in a parking lot adjacent to her place of employment at
5073 Ritter Road, Mechanicsburg, Pennsylvania 17055.
6. The Plaintiff was advised to park at this parking lot by her employer, Delta
Dental Corporation and the Defendant, High Associates.
7. At said time and place, the Plaintiff began walking from her car towards
the entrance of the building located at 5073 Ritter Road, Mechanicsburg,
Pennsylvania.
8. At said time and place, the Plaintiff stepped into a pothole in the parking
lot twisting her back and causing her to fall.
9. The injuries sustained by the Plaintiff were caused by the negligence and
carelessness of the Defendant, High Associates Limited which consists of
the following:
(a) Improper maintenance of a parking lot.
(b) Failure to properly fix potholes in a parking lot.
(c) Failure to fix a hazardous condition in the parking lot after having
notice of the problems from prior falls.
(d) Failure to keep a parking lot even while people are walking from
their cars to the commercial building to walk safely to the
commercial building.
10. At all times material hereto, the actions and conduct of the Plaintiff did not
in anyway contribute to the injuries sustained by the Plaintiff.
11. As a result of the fall sustained by the Plaintiff, she suffered severe
personal injuries. These injuries include by are not limited to:
lumbosacral strain sprain, shoulder sprain strain, cervical sprain
strain, aggravation of cervical degenerative disease, herniated disc at the
L-4 L-5 level, herniated disc at the L-5 S-1 level, lumbosacral sprain
strain, aggravation of degenerative joint disease in the lumbar and
cervical spine, myofascial pain syndrome of the lumbar and cervical spine
lumbar segmental dysfunction, lumbar IVD displacement w/o
myelopathy, pelvic segmental, sacroiliac segment dysfunction,
abnormality of gait and lumbalgia.
12. As a sole and proximate result of the fall, the Plaintiff has incurred various
medical expenses and in the future will incur various medical expenses
and miscellaneous expenses. The total amount of which is unascertained at
this time.
13. As a sole and proximate result of the fall, the Plaintiff has suffered from a
loss of income and wages from work. The total amount of this loss is
unascertained at this time.
14. As a sole and proximate result of the fall, the Plaintiff has been advised
and therefore avers that she will have permanent residual physical
problems.
15. As a sole and proximate result of the fall, the Plaintiff has undergone in
the past great pain and suffering and will in the future will undergo great
pain and suffering.
16. As a sole and proximate result of the fall, the Plaintiff has had to severely
limit her activities of daily living.
WHEREFORE, the Plaintiff prays this Honorable Court enter judgment against
the Defendant in the amount less than Fifty Thousand Dollars ($50,000.00), an amount
requiring compulsory arbitration.
Respectfully submitted,
By: /
Dixon, Esquire
Attorney ID No. 28290
126 State Street
Harrisburg, PA 17101
(717) 236-8515
s- Attorney for the Plaintiff
L
Dated: `'
VERIFICATION
I verify that the statements made in this Aw?,IIV4,1 , are true and
correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S.
§4904, relating to unworn falsification to authorities.
o,m .? a?
CERTIFICATE OF SERVICE
AND NOW, this 24th day of March, 2008, I, Joseph J. Dixon, Esquire, hereby certify that
I have served a true and correct copy of the foregoing document this day by depositing the same
the same in the United States Mail, first class, postage prepaid, in the Post Office at Harrisburg,
Pennsylvania, addressed to:
MEGHAN K. FINNERTY, ESQUIRE
POST & SCHELL
1857 WILLIAM PENN WAY
P.O. BOX 10248
LANCASTER, PA 17605-0248
By. ,--,
J eph J. Dixon, Esquire
Attorney ID No. 28290
126 State Street
Harrisburg, PA 17101
(717) 236-8515
Attorney for Plaintiff
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POST & SCHELL, P.C.
BY: PAUL W. GREGO
I.D. #:39701
1857 WILLIAM PENN WAY
P.O. BOX 10248
LANCASTER, PA 17605-0248
717-291-4532
HELEN BRIDGES
Plaintiff,
V.
HIGH ASSOCIATES, LTD.
Defendant.
ATTORNEYS FOR DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 3244-2007 CIVIL TERM
JURY TRIAL DEMANDED
NOW INTO COURT, through undersigned counsel, comes the Defendant, High
Associates, Ltd., who, in answer to the Complaint of the Plaintiff, respectfully represents that:
1. Denied. After reasonable investigation, the responding party is without
knowledge or information sufficient to form a belief as to the truth of these averments and strict
proof thereof is demanded.
2. Denied as stated. It is admitted that Defendant High Associates, Ltd. is a
Pennsylvania business organization. The remaining averments of this paragraph are denied. To
the contrary, while Defendant has an office at the address alleged, the principal place of business
of High Associates, Ltd. is 1853 William Penn Way, in Lancaster, Pennsylvania.
3. Denied as stated. To the contrary, the referenced building was owned by High
Properties, a limited partnership.
4.-16. Defendant, pursuant to Pennsylvania Rules of Civil Procedure 1029(e), hereby
generally denies the remaining allegations of the Complaint. Further, strict proof of all relevant
averments is demanded at trial.
WHEREFORE, Defendant prays that the Complaint be dismissed, at the cost of the
Plaintiffs.
NEW MATTER
17. Plaintiffs' claims are barred to the extent it is established that Plaintiffs have
failed to join a necessary party to this litigation.
18. Plaintiffs' claims are barred and/or limited by the Pennsylvania Comparative
Negligence Act to the extent it is established that the actions and/or inactions of Helen Bridges
caused or contributed to the incident complained of.
19. Plaintiffs' Complaint is barred by the applicable statute of limitations.
20. Plaintiffs' claims are barred to the extent it is established that Plaintiffs have
failed to mitigate their damages.
21. Plaintiffs' claims for out-of-pocket medical specials, if any, are limited to the
amount received by Plaintiffs' providers in satisfaction of the charges in question, or the amount
of the bills for services rendered, whichever is less.
22. Plaintiffs' claims are barred by the Doctrine of Release, Setoff and/or Accord and
Satisfaction to the extent it is established that Plaintiffs have entered into any agreements,
settlements or releases concerning this incident or the damages allegedly sustained by her.
23. Plaintiffs' claims may be barred by the Doctrines of Intervening/Superseding
Causes.
24. Any defect alleged in Plaintiff's complaint is a trivial defect not actionable as a
matter of law.
25. Defendant desires, and is entitled to, a trial by jury.
-2-
WHEREFORE, Answering Defendant demands judgment in their favor and against
Plaintiff, together with such other relief as this Honorable Court may deem just and appropriate.
Respectfully submitted:
POST & SCHELL, P.C.
By: b ?/Vl?
Paul W. Grego
Attorney for Defendant
High Associates, Ltd.
Date: March 27, 2008
-3-
Re: Helen Bridges v High Associates
VERIFICATION
I HEREBY VERIFY that the statements made in the foregoing document are true and
correct to the best of my knowledge, information and belief. I understand that any false
statements contained herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unworn falsification to authorities.
I certify that I am a duly authorized representative of HIGH ASSOCIATES, and, as such,
am authorized to make this Verification on its behalf.
HIGH ASSOCIATES
CERTIFICATE OF SERVICE
I, Lilly A. Torres, an employee of the law offices of Post & Schell, P.C., do hereby
certify that on the date set forth below, I did serve a true and correct copy of the foregoing
document upon the following person(s) at the following address(es) by sending same in the
United States mail, first-class, postage prepaid:
Joseph J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
DATE: _`??
LILLY A. TO S
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CERTIFICATE ohi
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
HIGH ASSOCIATES,
.As a prerequisit
to Rule 4009.22
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
LTD.
e to service of a subpoena for documents and things pursuant
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
S b aleok,-10
DATE: 04/21/2008 INNE ttorney for T
R1.57 118-H DE11-0746564 70852-LO1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
SKOCIK CHRIROPRACTIC
COMMUNITY GENERAL OSTEO.
JAY CHO, M.D.
TRINDLE REHABILITATION C
ABDULAI M. BUKARI
PA DENTAL SERVICE CORP.
DONEGAL MUTUAL INSURANCE
MEDICAL RECORDS
HOSP. MEDICAL RECORDS
MEDICAL RECORDS
ENTER MEDICAL RECORDS
MEDICAL RECORDS
EMPLOYMENT
CO. INSURANCE
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 04/01/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.49S 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-0389849 70852 -COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
File No. 3244-2007
vs.
HIGH ASSOCIATES, LTD.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for SKOCIK CHRIROPRACTIC
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at _ The MCS Group. Inc 1601 Market Street, Suite 800 Philadelphia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY, ESQ.
ADDRESS: 1857 WILLIAM PENN WAY
PO BOX 10248
LANCASTER. PA 17605
TELEPHONE:. (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY THE OURT:
Prot onotary/ ,Civil ivision
Ions Deputy
OYA
Date: -=fa
Sea] of the Court
70852-01
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
SKOCIK CHRIROPRACTIC
5500 ALLENTOWN BLVD.
HARRISBURG, PA 17112
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.49S 116-H SU10-0727526 70852 -LOl
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
w
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
CASE NO: 3244-2007
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY, ES
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 04/21/2008
ICS on beh of
NNER S
Aftorney fo ENDANT
R1.57 118-13 DE11-0746565 70852 -L02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
SKOCIK CHRIROPRACTIC
COMMUNITY GENERAL OSTEO. HOSP
JAY CHO, M.D.
TRINDLE REHABILITATION CENTER
ABDULAI M. BUKARI
PA DENTAL SERVICE CORP.
DONEGAL MUTUAL INSURANCE CO.
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
EMPLOYMENT
INSURANCE
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 04/01/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
RI -49S 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC .
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-0389849 70852-COI
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO
Custodian of Records for COMMUNITY GENERAL OSTEO HOSP
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at _ The MCS Group Inc 1601 Market Street Suite 800, Philadelphia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY. ESO.
ADDRESS: 1857 WILLIAM PENN WAY
PO BOX 10248
LANCASTER. PA 17605
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
o o
Date: 3/o4G?o?t
Seal of the Court
BY TH COURT:
Pr onotary/ C' iI Division
Deputy
70852-02
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
COMMUNITY GENERAL OSTEO. HOSP.
MEDICAL RECORDS
4300 LONDONBERRY RD
HARRISBURG, PA 17109
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire hospital medical file, including but not limited to any and all records,
correspondence to and from the consulting and/or treating physician, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, nurse's notes, doctor's comments, dietary restrictions,
and all patient consent or refusal of treatment, procedures, test, and/or
medication, lab and diagnostic test results, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, diagnosis, care, treatment,
admission, discharge, or emergency care pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.49S 116-H Sv10-0727528 70852-LO2
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
HIGH ASSOCIATES,
As a prerequisit
to Rule 4009.22
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
LTD.
e to service of a subpoena for documents and things pursuant
MCS on behalf of MEGHAN FINNERTY, ES
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
*Attorney b , aWER
DATE: 04/21/2008 INNfoR1.57 118-14 DE11-0746566 70852 -L03
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2 007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
SKOCIK CHRIROPRACTIC
COMMUNITY GENERAL OSTEO.
JAY CHO, M..D.
TRINDLE REHABILITATION C
ABDULAI M. BUKARI
PA DENTAL SERVICE CORP.
DONEGAL MUTUAL INSURANCE
MEDICAL RECORDS
HOSP. MEDICAL RECORDS
MEDICAL RECORDS
ENTER MEDICAL RECORDS
MEDICAL RECORDS
EMPLOYMENT
CO. INSURANCE
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice peri od is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 04/01/2008
CC:: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
RI-49S 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-0389849 70852 -COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
File No. 3244-2007
HIGH ASSOCIATES, LTD.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for JAY CHO M.D.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at _ The MCS Groun. Inc.. 1601 Market Street Site 800 Philadelphia. PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY, ESO.
ADDRESS: 1857 WILLIAM PENN WAY
PO BOX 10248
LANCASTER. PA 17605
TELEPHONE: (215) 246-0900
SUPREME COURT ID 4:
ATTORNEY FOR: Defendant
^
Date: 3A& -p
Seal of the Court
BY THE COURT:
Pro onotary/ r . Civ' Division
Deputy
70852-03
EXPLANATION OF REQUIRED RECORDS
FO: CUSTODIAN OF RECORDS FOR
,JAY CHO, M.D.
REHAB MEDICINE ASSOC.
5124 E. TRINDLE RD.
MECHANICSBURG, PA 17055
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.49S 116-H SU10-0727530 70852-L03
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA ORIGIN141
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
CUMBERLAND
-VS-
HIGH ASSOCIATES, LTD.
CASE NO: 3244-2007
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 04/21/2008
on b 1 f
INN
E Q
ttorney folz-bEFENDANT
R1.57 118-H DE11-0746567 70852 -L04
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
SKOCIK CHRIROPRACTIC
COMMUNITY GENERAL OSTEO. HOSP
JAY CHO, M.D.
TRINDLE REHABILITATION CENTER
ABDULAI M. BUKARI
PA DENTAL SERVICE CORP.
DONEGAL MUTUAL INSURANCE CO.
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
EMPLOYMENT
INSURANCE
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 04/01/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
RI-49S 116--H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC .
1601 MARKET STRE-ET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-0389849 70852 -COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for TRINDLE REHABILITATION CENTER
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at _ The MCS Grouo Inc 1601 Market Street Suite 800. Philadelphia. PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY. ESQ.
ADDRESS: 1857 WILLIAM PENN WAY
PO BOX 10248
LANCASTER.' PA 17605
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: ??02 8
Seal of the Court
BY THE OURT:
Protlxonotary/C ivil ivision
Deputy
70852-04
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
--RINDLE REHABILITATION CENTER
5124 EAST TRINDLE RD.
MECHANICSBURG, PA 17055
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.49S 116-H SU10-0727532 70852 -LO4
CERTIFICATE 9 `f? Plt = r
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
CUMBERLAND
-VS-
HIGH ASSOCIATES, LTD.
CASE NO: 3244-2007
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 04/21/2008
on eha of
ERTX S .
orney for " FENDANT
R1.57 118-H DE11-0746568 70852 -L05
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2 007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
SKOCIK CHRIROPRACTIC
COMMUNITY GENERAL OSTEO.
JAY CHO, M.D.
TRINDLE REHABILITATION C
ABDULAI M. BUKARI
PA DENTAL SERVICE CORP.
DONEGAL MUTUAL INSURANCE
MEDICAL RECORDS
HOSP. MEDICAL RECORDS
MEDICAL RECORDS
ENTER MEDICAL RECORDS
MEDICAL RECORDS
EMPLOYMENT
CO. INSURANCE
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MC:S on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 04/01/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.49S 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-0389849 70852 -COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for ABDULAI M. BUKARI
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at _ The MCS Group_ Inc.. 1601 Market Street. Suite 800. Philadelphia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY, ESQ.
ADDRESS: .1857 WILLIAM PENN WAY
PO BOX 10248
LANCASTER. PA 17605
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY THE URT:
Protho otary/Cler it Di Sion
Date: tiPR 12008 Deputy
3 s??IK
Seal of the Court
70852-05
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
ABDULAI M. BUKARI
43 KLINE VILLAGE
HARRISBURG, PA 17104
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.49S 116-H SU10-0727534 70852 -L05
7"e- J'f
CERTIFICATE f ',. `
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
CUMBERLAND
-VS -
CASE NO: 3244-2007
HIGH ASSOCIATES, LTD.
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 04/21/2008
o f o
go R Q.
Attorney fo FENDANT
R1.57 118-H DE11-0746569 70852 -L06
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF':
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-.2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
SKOCIK CHRIROPRACTIC
COMMUNITY GENERAL OSTEO. HOSP
JAY CHO, M.D.
TRINDLE REHABILITATION CENTER
ABDULAI M. BUKARI
PA DENTAL SERVICE CORP.
DONEGAL MUTUAL INSURANCE CO.
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
MEDICAL RECORDS
EMPLOYMENT
INSURANCE
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 04/01/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.49S 116--H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC .
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-0389849 70852 -C01
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for PA DENTAL SERVICE CORP
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at _ The MCS Group Inc 1601 Market Street. Suite 800 Philadelphia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY. ESQ.
ADDRESS: 1857 WILLIAM PENN WAY
PO BOX 10248
LANCASTER PA 17605
TELEPHONE: (215) 246-0900
SUPREME COURT ID 4:
ATTORNEY FOR: Defendant
APLD
Date: 3?Z&Lo 8
Seal of the Court
BY THE C URT:
Protho otary/Clerk, ivi on
Deputy
70852-06
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
FA DENTAL SERVICE CORP.
1 DELTA DRIVE
MECHANICSBURG, PA 17055
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
INCLUDING ANY COMPLAINTS TO HIGH INDUSTRIES REGARDING THE ADJOINING
PARKING LOTS.
Any and all employment records, applications, files, memoranda, compensation,
time and attendance records, personnel records, payroll and salary reports and
all medical records as an employee, including any and all such items as may be
stored in a computer database or otherwise in electronic form, pertaining to:
Dates Requested: up to and including the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.49S 116-H SU10-0727536 70852 -L06
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
olqlky &I ?.
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
CASE NO: 3244-2007
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 04/21/2008
+ttorney be f of
NNERT E Q .
for' FENDANT
R1.57 118-H DE11-0746570 70852 -L07
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2 007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
SKOCIK CHRIROPRACTIC
COMMUNITY GENERAL OSTEO.
JAY CHO, M.D.
TRINDLE REHABILITATION C
ABDULAI M. BUKARI
PA DENTAL SERVICE CORP.
DONEGAL MUTUAL INSURANCE
MEDICAL RECORDS
HOSP. MEDICAL, RECORDS
MEDICAL RECORDS
;NTER MEDICAL RECORDS
MEDICAL RECORDS
EMPLOYMENT
CO. INSURANCE
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 04/01/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1-49S 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC .
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-0389849 70852 -C01
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for DONEGAL MUTUAL INSURANCE CO.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at _ The MCS Group. I 1601 Market Street Suite 800 Philadelphia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY, ESQ.
ADDRESS: 1857 WILLIAM PENN WAY
PO BOX 10248
LANCASTER. PA 17605
TELEPHONE: (215) 246-0900
SUPREME COURT ID 4:
ATTORNEY FOR: Defendant
w i.JeiT'
'APR
Date: Toy
Sea] of the Court
BY THE URT:
Prothonotary /Cler vil D' ision
Deputy
70852-07
***O - copies of any and all documents contained within your file, including, but not limited to,
the entire file from cover to cover, including all applications for benefits, all records, all benefits,
payment data, all applications for benefits forms, all medical records, correspondence,
explanation of benefit forms, UM/UIM claims records, property damage records, medical
payments benefits, lost wage benefits and/or information relating to said lost wages, photographs
and statements relating to any and all automobile accidents involving Plaintiff and/or claims
submitted by Plaintiff Helen Bridges ; Policy Number PAE-0491980-13.
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
DONEGAL MUTUAL INSURANCE CO.
1195 RIVER ROAD
P.O. BOX 302
MARIETTA, PA 17547
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
***SEE ATTACHED***
Dates Requested: up to and including the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.49S 116-H SU10-0727538 70852 -L07
r I ? ! ttY bW
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
HIGH ASSOCIATES, LTD.
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 06/03/2008
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
R1.61 116-H DE11-07SS427 70852-LO8
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
-VS- CASE NO: 3244-2007
HIGH ASSOCIATES,.LTD.
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
KLINE FAMILY PRACTICE CENTER MEDICAL RECORDS
CONCENTRA MEDICAL CENTER MEDICAL RECORDS
MALIK N. MOMIN, M.D. MEDICAL RECORDS
HAMILTON HEALTH CENTER MEDICAL RECORDS
JAMES C. MILLER, D.O. MEDICAL RECORDS
DR. MUMMA MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 05/14/2008
MCS on behalf of
MEGHAN FINNERTY; ESQ.
Attorney for DEFENDANT
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.61 116-H
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103:
(215) 246-0900
DE02-0393710 70852-COI
COMMONWEALTH QF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for KLINE FAMILY PRACTICE CENTER
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Grove. Inc. , 1601 Market Stree Suite 800 Philaddg}j, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY, E
ADDRESS: 1857 WILLIAM PENN W
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
JUN 0 8 2008
Date: -W
Seal of the Court
BY COURT.
I A41?
466khhonotary/Clerk, Civil Avi?
Deputy
70852-08
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
KLINE FAMILY PRACTICE CENTER
2501 N. THIRD STREET
HARRISBURG, PA 17110
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports,.medication/
prescription records, including any and all such items as may be stored in.a;
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R1.61 116-H
SU10-0734778 70852-LO8
4r' j LL? , ? ? ?fi?8
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
COURT OF COMMON PLEAS
HELEN BRIDGES
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
HIGH ASSOCIATES, LTD.
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 0610312008 MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
R1.61 116-H
D811-0755428 70852-L09
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
-VS- CASE NO: 3244-2007
HIGH ASSOCIATES,.LTD.
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
KLINE FAMILY PRACTICE CENTER MEDICAL RECORDS*
CONCENTRA MEDICAL CENTER MEDICAL RECORDS
MALIK N. MOMIN, M.D. MEDICAL RECORDS
HAMILTON HEALTH CENTER MEDICAL RECORDS
JAMES C. MILLER, D.O. MEDICAL RECORDS
DR. MUMMA MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You-have twenty '(20)
days from the date listed below in which to file of record and serve`upon`the
undersigned an objection to the subpoena. If the twenty day notice period, is
waived.or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 05/14/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.61 116-H
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, 'PA .,19103
(215) 246-0900
D902-0393710 70852-CO1
COMMONWEALTH _OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
File No. 3244-2007
VS.
HIGH ASSOCIATES, LTD.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for CONCENTRA MEDICAL CENTER
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at _ The MCS =- Inc., 1601 Market Street, Suite 800, P it A labia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY. ES
ADDRESS: 1857 WILLIAM PENN WA
TELEPHONE: _(215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
JUN 0 3 2008
Date: ffl-'j?!
Seal of the Court
BY COURT:
thonotary/Clerk, 4Divi
eputy
70852-09
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
CONCENTRA MEDICAL CENTER
4910 RITTER ROAD
MECHANICSBURG, PA 17055
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals,4100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : 88LBN BRIDGES
,
Social Security #: X88-XX-5171
Date of Births 12-10-1964
R1.61 116-H
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
HIGH ASSOCIATES,
As a prerequisit
to Rule 4009.22
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
LTD.
e to service of a subpoena for documents and things pursuant
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 06/03/2008
R1.61 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
DE11-0755429 70852-LIO
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, .LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
KLINE FAMILY PRACTICE CENTER MEDICAL RECORDS
CONCENTRA MEDICAL CENTER MEDICAL RECORDS
MALIK N. MOMIN, M.D. MEDICAL RECORDS
HAMILTON HEALTH CENTER MEDICAL RECORDS
JAMES C. MILLER, D.O. MEDICAL RECORDS
DR. MUMMA MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You.have twenty,(20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice peri6d is
waived.or if no objection is made, then the subpoena may be served. eompl:ete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 05/14/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.61 116-H
MCS on behalf of
MEGHAN FINNERTY,, ESQ.
Attorney for'•DEkt!4DANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
D202-0393710 70852-COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
File No. 3244-2007
VS.
HIGH ASSOCIATES, LTD.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for MALIK N. MOM1N, M.D.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED MU ****
at The MCS C==- Inc., 1601 Market Street Suite 800, P ilad is-PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAAN FINNERTY. ES
ADDRESS: 1857 WILLIAM PENN WA
TELEPHONE: (215) 246-0900
COURT ID #:
ATTORNEY FOR: Defendant
JUN 0 3 2008
Date: / •(?y n1 . 2066
Seal of the Court
BY THE OURT: '-? j
or4
rothonotary/Clerk, Civil Divisi
Deputy
70852-10
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
MALIK N. MOMIN, M.D.
PAIN MANAGEMENT
825 SIR THOMAS
HARRISBURG, PA 17109
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all'.records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as play be stored in,a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : BELEN BRIDGES
social Security #: EEX-XX-5171
Date of Birth: 12-10-1964
R1.61 116-H
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELBN .BRTDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
CASE NO: 3244-2007
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of MEGHAN FINNERTY ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 06/03/2008
R1.61 116-H
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
DE11-0755430 70852-Lll
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
_VS_
HIGH ASSOCIATES, .LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
KLINE FAMILY PRACTICE CENTER MEDICAL RECORDS'
CONCENTRA MEDICAL CENTER MEDICAL RECORDS
MALIK N. MOMIN, M.D. MEDICAL RECORDS
HAMILTON HEALTH CENTER MEDICAL RECORDS
JAMES C. MILLER, D.O. MEDICAL RECORDS
DR. MUMMA MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice peril is
waived-or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by.completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 05/14/2008
1
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.61 116-H
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(21.5) 246-0900
D$02-0393710 70852-C01
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
VS.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for HAMILTON HEALTH CENTEIR
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The M . T= Inc-, 1601 Market Street Suite 800, P it rt ia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNER
ADDRESS: 1857 Wi I JAM PM
TELEPHONE: (2151246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
JUN 0 3 2008
Date: `1v
Seal of the Court
BY THE OURT:
Igrothonotary/Clerk, Civil Di on
Deputy .
70852-11
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HAMILTON HEALTH CENTER
1821 FULTON STREET
HARRISBURG. PA 17102
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating. to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject HELEN BRIDGES
Social Security #: EEE-XX-5171
Date of Birth: 12-10-1964
MIG416W w 'r k4
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
HIGH ASSOCIATES,
As a prerequisit
to Rule 4009.22
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
LTD.
e to service of a subpoena for documents and things pursuant
MCS on behalf of _ MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 06/03/2008
R1.61 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
DE11-0755431 70852-L12
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-vs-
HIGH ASSOCIATES,.LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
KLINE FAMILY PRACTICE CENTER MEDICAL RECORDS
CONCENTRA MEDICAL CENTER MEDICAL RECORDS
MALIK N. MOMIN, M.D. MEDICAL RECORDS
HAMILTON HEALTH CENTER MEDICAL RECORDS
JAMES C. MILLER, D.O. MEDICAL RECORDS
DR. MUMMA MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice per g',d is
waived.or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by.>completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 05/14/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
R1.61 116-H
MCS on behalf of
MEGHAN FINNERTY,. ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103 `.
(215) 246-0`900
DE02-0393710 70852-COI
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
VS.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for JAMES C. MILLER. D.O.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The M Ca=- Incj„ 1601 Market 4 Suite 500, P it dpi PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: MEGHAN FINNERTY, ESQ.
ADDRESS: 1857 WILLIAM PENN WAY
PO BOX 10248
_LANCASTER. PA 17605
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
JUN 0 9 2008
Date: Q,
Seal of the Court
BY THE OURT:
0 onotary/Clerk, Civil Divi
96
eputy
70852-12
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
JAMES C. MILLER. D.O.
UNIVERSITY PHYSICIANS
1711 N FRONT STREET
HARRISBURG. PA 17102
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items.as may be stored in a
computer database or otherwise in electronic form,` relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
r
Social Security #: XXX-5E-5171
Date of Birth: 12-10-1964
R1.61 116-H
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
HIGH ASSOCIATES,
As a prerequi.sit
to Rule 4009.22
cl?IG1111?" "
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
LTD.
e to service of a subpoena for documents and things pursuant
MCS on behalf of MEGHAN FINNERTY, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 06/03/2008
R1.61 116-H
MCS on behalf of
MEGHAN FINNERTY, ESQ.
Attorney for DEFENDANT
DE11-0755432 70852-L13
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES,.LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOMA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
KLINE FAMILY PRACTICE CENTER MEDICAL RECORDS
CONCENTRA MEDICAL CENTER MEDICAL RECORDS
MALIK N. MOMIN, M.D. MEDICAL RECORDS
HAMILTON HEALTH CENTER MEDICAL RECORDS
JAMES C. MILLER, D.O. MEDICAL RECORDS
DR. MUMMA MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of MEGHAN FINNERTY, ESQ. intends to serve a .subpoena
identical to the one that is attached to this notice. You have twenty, (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day naticd period is
waived or if no objection is made, then the subpoena may be, served.,Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 05/14/2008
CC: MEGHAN FINNERTY, ESQ. - 175-135439
Any questions regarding this matter, contact
11.61 116-H
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103,
(215) 246-0900
D802-0393710 70852 -CO1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
VS.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for DR MUMMA
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The M CUM- Inc 1601 Madmi Street, Suite 800 Phila&Whia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
TELEPHONE: 15) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
JUN 0 3 2008
Date: J
T
Seal of the Court
BY 70URT:
0 onotarylClerk, Civil ivi o
Deputy
70852=13
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
DR. MUMMA
175 LANCASTER BLVD.
MECHANICSBURG, PA 17055
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from% 01-01-1970 to the present:
Subject s HELEN BRIDGES
Social Security #s XXX-XX-5171
Date of Births 12-10-1964
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
HIGH ASSOCIATES,
As a prerequisit
to Rule 4009.22
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
LTD.
e to service of a subpoena for documents and things pursuant
MCS on behalf of PAUL W. GREGO, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 08/25/2008
MC on be///h l f f
/AUL
W. GREGO, SQ. '
Attorney for FE ANT
R1.87 133-H DE11-0775319 70852-L14
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMMIS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
GREGORY S. WILLIS, DO MEDICAL RECORDS
WEBER OB/GYN ASSOCIATES MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on behalf of PAUL W. GREGO, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE 08/05/2008
CC:'"PAUL°W. GREGO, ESQ. - 175-135439
Any questions regarding this matter, contact
JOSEPH J. DIXON, ESQ.
126 STATE STREET
HARRISBURG, PA 17101
MCS on behalf of
PAUL W. GREGO, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA,- PA 19103.
(215) 246-0900
R1.83 116-H D202-0400257` '7O$52-COI
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
File No. 3244-2007
VS.
HIGH ASSOCIATES, LTD.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for GREGORY S WILLIS DO
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at The MCS Groun Inc 1601 Market Street. Suite 800, Philadelphia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: PAUL W. GREGO, ES
ADDRESS: 1857 WILLIAM PENT
TELEPHONE: (715) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY COURT:
Pr onotary/CI , ivil ivision
Deputy
Date:
Seal of the Court
70852-14
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
GREGORY S. WILLIS, DO
3901 N. FRONT
HARRISBURG. PA 17110
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
,
Social Security *: XXX-XX-5171
Date of Birth: 12-10-1964
R1.83 116-H SU10-0745594 70852-L14
• CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
CUMBERLAND
-VS-
CASE NO: 3244-2007
HIGH ASSOCIATES, LTD.
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of PAUL W. GREGO, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 08/25/2008
M jon behalf of
l W . ('fir • o
/ AUL W. GREGO, 03Q
Attorney for D ENDANT
R1.87 133-H DE11-0775320 70852-L15
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
HELEN BRIDGES
-VS-
HIGH ASSOCIATES, LTD.
COURT OF COMMON PLEAS
TERM,
CASE NO: 3244-2007
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
GREGORY S. WILLIS, DO MEDICAL RECORDS
WEBER OB/GYN ASSOCIATES MEDICAL RECORDS
TO: JOSEPH J. DIXON, ESQ., PLAINTIFF COUNSEL
MCS on`behalf of PAUL W. GREGO, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCSoffice.
DATE: 08/05/2008
cc: PAUL W. GREGO, ESQ.
MCS on behalf of
PAUL W. GREGO, ESQ.
Attorney for DEFENDANT
175-135439
Any questions regarding this matter, contact
JOSEPH J. DIXON, ESQ.
126 STATE STREET
HARRISBURG, PA 17101
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
R1.83 116-H DE02-0400257 708552-COl
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for WEBER OB/GYN ASSOCIATES
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at The MCS Group, Inc.. 1601 Market Street. Suite 800. Philadelphia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: PAUL W. GREGO, ES
ADDRESS: 1857 WILLIAM P
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY T COURT:
? !b6
Pr onotary/Cle , iv Division
hi n Deputy
Date:
Seal of the Court
70852-15
. EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
WEBER OB/GYN ASSOCIATES
100 S.2ND ST. 4A
HARRISBURG. PA 17101
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXE-Ea-5171
Date of Birth: 12-10-1964
R1.83 116-H
SU10-0745596 70852-L15
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POST & SCHELL, P.C.
BY: PAUL W. GREGO
I.D. #: 39701
1857 WILLIAM PENN WAY
P.O. BOX 10248
LANCASTER, PA 17605-0248
717-291-4532
HELEN BRIDGES
V.
Plaintiff,
HIGH ASSOCIATES, LTD.
Defendant.
ATTORNEYS FOR DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 3244-2007 CIVIL TERM
JURY TRIAL DEMANDED
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Paul W. Grego, counsel for the Defendant in the above action, respectfully represents
that:
1. The above-captioned action is at issue.
2. The claim of Plaintiff in the action is less than $50.000.
The counterclaim of the Defendant in the action is 0
The following attorney(s) are interested in the case as counsel or are otherwise
disqualified to sit as arbitrators: Joseph J. Dixon, Esquire.
WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
POST & SC LL, P.C.
f
By:
Paul W. Grego
Attorney for Defend
High Associates, Ltd.
i
CERTIFICATE OF SERVICE
I, Sandra Morales, an employee of the law offices of Post & Schell, P.C., do hereby
certify that on the date set forth below, I did serve a true and correct copy of the foregoing
document upon the following person(s) at the following address(es) by sending same in the
United States mail, first-class, postage prepaid:
Joseph J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
SANDRA MORALES
DATE: o? 3 a S _3 3
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HELEN BRIDGES, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
HIGH ASSOCIATES, LTD,
DEFENDANT 07-3244 CIVIL TERM
ORDER OF COURT
AND NOW, this Z1 day of April, 2009, the appointment of a Board
of Arbitrators in the above-captioned case, IS VACATED. Keith O. Brenneman,
Esquire, Chairman, shall be paid the sum of $50.00.
Keith O. Brenneman, Esquire
Court Administrator
:sal
By the
Edgar B. Bayley, J.
fR-
C-j
r
Defendant.
ATTORNEYS FOR DEFENDANT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO: 3244-2007 CIVIL TERM
JURY TRIAL DEMANDED
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Paul W. Grego, counsel for the Defendant in the above action, respectfully represents
that:
1. The above-captioned action is at issue.
2. The claim of Plaintiff in the action is less than $50,000.
The counterclaim of the Defendant in the action is 0
The following attorney(s) are interested in the case as counsel or are otherwise
disqualified to sit as arbitrators: Joseph J. Dixon, Esquire.
WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
POST & SCHE , P.C.
By:
Paul W. Grego
Attorney for Defendant
High Associates, Ltd.
POST & SCHELL, P.C.
BY: PAUL W. GREGO
I.D. #: 39701
1857 WILLIAM PENN WAY
P.O. BOX 10248
LANCASTER, PA 17605-0248
717-291-4532
HELEN BRIDGES
V.
Plaintiff,
HIGH ASSOCIATES, LTD.
CERTIFICATE OF SERVICE
I, Sandra Morales, an employee of the law offices of Post & Schell, P.C., do hereby
certify that on the date set forth below, I did serve a true and correct copy of the foregoing
document upon the following person(s) at the following address(es) by sending same in the
United States mail, first-class, postage prepaid:
Joseph J. Dixon, Esquire
126 State Street
Harrisburg, PA 17101
SANDRA MORALES
DATE: '7/ /o/07
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ORDER OF COURT
AND NOW, •'1 2009, in consideration of the foregoing
Petition, Esq., and
Esq., and r)Jjl-jm m? Esq., are appointed arbitrators in the above
captioned action as prayed for.
BY URT,
.. 1 G
EDGAR B. BAYLEY
2
OF VIE FRC IF: ?!AIRiY
2099 SEP 24 PH 4: 2J
INTY
9/?S/Dq - LAS /K;ttLc
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
CUMBERLAND
-VS-
CASE NO: 3244-2007
HIGH ASSOCIATES, LTD.
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of PAUL W. GREGO, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 10/08/2009
mCS on behalf of
/S/ Paa V (recto,
PAUL W. GREGO, ESQ.
Attorney for DEFENDANT
R2.19 116-H DE11-0988955 70852-L16
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for TRISTAN ASSOCIATES
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at The MCS Group, Inc. 1601 Market Street Suite 800-Philadelphia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: PAUL W. GREGO, ES
ADDRESS: 1857 WILLIAM PENT
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
OCT 0 8
Date: I - 023 o2&U 9
Seal of the Court
BY THE COURT:
1,( P,,.a- P '-,
Prothonotary/Clerk, Civil Division
Deputy
70852-16
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
TRISTAN ASSOCIATES
4518 UNION DEPOSIT ROAD
HARRISBURG, PA 17111
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical and x-ray file, including but not limited to any and all
records, correspondence to and from the treating and consulting physicians,
files, memoranda, handwritten notes, history and physical reports, x-ray films
and reports, medication/prescription records, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, care or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R2.19 116-H SU10-0804672 70852-L16
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
HELEN BRIDGES TERM,
CUMBERLAND
-VS-
CASE NO: 3244-2007
HIGH ASSOCIATES, LTD.
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of PAUL W. GREGO, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 10/08/2009
MCS on behalf of
/S/ Paul UV. q.j e o,
PAUL W. GREGO, ESQ.
Attorney for DEFENDANT
R2.19 116-H DE11-0988959 70852-L17
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO
Custodian of Records for__ QUANTUM IMAGING
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at The MCS Group, Inc. 1601 Market Street Suite 800, Philadelphia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: PAUL W. GREGO. ES
ADDRESS: 1857 WILLIAM PENT
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY THE COURT:
X51 "- oe
Prothonotary/Clerk, Civil ivision
OCT 0 8 2009 t
4&4? .23c;2 ev Deputy 9
Seal of the Court
70852-17
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
QUANTUM IMAGING
405 SAINT JOHNS CHURCH RD
SUITE 102
CAMP HILL, PA 17011
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical and x-ray file, including but not limited to any and all
records, correspondence to and from the treating and consulting physicians,
files, memoranda, handwritten notes, history and physical reports, x-ray films
and reports, medication/prescription records, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, care or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R2.19 116-H SU10-0804674 70852-L17
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
HELEN BRIDGES
HIGH ASSOCIATES,
As a prerequisit
to Rule 4009.22
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
-VS- CASE NO: 3244-2007
LTD.
e to service of a subpoena for documents and things pursuant
MCS on behalf of PAUL W. GREGO, ES
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 10/08/2009
MCS on behalf/ of
/S/ Laa l/V. (j ego, 64.
PAUL W. GREGO, ESQ.
Attorney for DEFENDANT
R2.19 116-H DE11-0988962 70852-L18
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HELEN BRIDGES
vs.
HIGH ASSOCIATES, LTD.
File No. 3244-2007
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO
Custodian of Records for MAGNETIC IMAGING CENTER
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: * * * * SEE ATTACHED RIDER * * * *
at The MCS Group Inc. 1601 Market Street, Suite 800, Philadelphia, PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: PAUL W. GREGO, ES
ADDRESS: 1857 WILLIAM PENT
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: _Defendant
OCT 0 8 2000
Date: l _?u'ft .v 12 3 02 " 9
Seal of the Court
BY THE COURT:
isr.
r?notary/Clerk, Civi?on
Dep ty
70852-18
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
MAGNETIC IMAGING CENTER
4665 TRINDLE ROAD
CAMP HILL. PA 17011
RE: 70852
HELEN BRIDGES
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical and x-ray file, including but not limited to any and all
records, correspondence to and from the treating and consulting physicians,
files, memoranda, handwritten notes, history and physical reports, x-ray films
and reports, medication/prescription records, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, care or treatment pertaining to:
Dates Requested: from: 01-01-1970 to the present.
Subject : HELEN BRIDGES
Social Security #: XXX-XX-5171
Date of Birth: 12-10-1964
R2.19 116-H SU10-0804676 70852-L18
1 ; r r,
HELEN BRIDGES,
Plaintiff
V.
HIGH ASSOCIATES,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 3244 2007 CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE TO SETTLE, DISCONTINUE AND END
Please mark the above-captioned Writ settled, discontinued and ended.
Respectfully submitted,
By:
Joseph J. Dixon, Esquire
Attorney No. 28290
126 State Street
Harrisburg, PA 17101
(717) 236-8515
Attorney for the Plaintiff
Date: 1 r?? L?/
,.
?Sr 1 t;''
?..-4 ( la- i?
7009