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Home My WebLink About07-4046ADEEB RASHEED, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :DOCKET NO.: ~'y- ~~f (o C i ~) ~ ~ r1 CIVIL ACTION -LAW JAMIE SMITH, :PERSONAL INJURY Defendant :JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE CUMBERLAND COUNTY PROTHONOTARY: Please issue a Writ of Summons in the above-captioned action. Writ of Summons shall be issued and forwarded to Sheriff for service upon: Jamie Smith 270 Spanglers Mill Road New Cumberland, PA 17070 CSHANE & HITCHINGS, LLC Date:; - j" - n ~ oseph L. Hit gs, E~ e Attorney LD.# 65551 4807 Jonestown Road, Suite 148 Harrisburg, Pennsylvania 17109 Telephone: (717) 657-3900 Fax: (717) 657-2060 Attorney for Plaintiff WRIT OF SUMMONS TO THE ABOVE MENTIONED NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Date: ~• P othonotary By: Deputy 1 ~' ~ ,. ff _. ~ ~ lT ~ ! ~ a . (4l ~ ~ ~ 1 ~~ ~ ~ :_ ~ i L r ~ ~ ~ ., c :~ ~ ~ cx~ --< 0 SHERIFF'S RETURN - OUT OF COUNTY CASE N0: 2007-04046 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RASHEED ADEEB VS SMITH JAMIE R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: SMITH JAMIE deputized the sheriff of YORK serve the within WRIT OF SUMMONS but was unable to locate Him in his bailiwick. He therefore County, Pennsylvania, to On July 30th 2007 this office was in receipt of the attached return from YORK Sheriff's Costs: So answerer-=~~ ~- Docketing 18.00 ~~ % ~ ~~~_ Out of County 9.00 -~f Surcharge 10.00 R. Thomas Kline Dep York County 42.40 Sheriff of Cumberland County Postage .5g 79.98 / v' f3 (v'~ 07/30/2007 MCSHANE & HITCHINGS Sworn and subscribe to before me this day of , A.D. i -~ COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST.,YORK, PA 17401 ~t SERVICE CALL (717)771-9601 SHERIFF SERVICE ~STI~'~1'1~S P ~OCESS RECEIPT and AFFIDAVIT OF RETURN P~A~ TYPE ONLY L/ME 1 THRU 12 DO NOT DETACH ANY COPE& 1 PLAINTIFF/SI 12. COURT NUMBER Adeeb RashAed - 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANTI ~! JamiQ Smith Writ of St>nmons WOS SERVE ~ 5 NAME OF INOIVtOUAI, COMPANY. CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY 70 BE LEVIED, ATTACHED. OR SOLO Jamie Smith 6 ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NQ ,CITY. BORO, TWP .STATE AND ZIP CODE) AT ~ 270 Spanglers Mill Road IVew Cumberland, PA 17070 _ _ 7. INDICATE SEF IVICE O PERSONAL l7 PERSON IN CHARGE V DEPUTIZE =1 CERT. MAIL U 1ST CLASS MAIL U POSTED U OTHER NOW u y , 20 I, SHERIFF OF TY, PA, do her y deputize the s riff of or rk COUNTY to execute this Wr~ d turn there ing to law. This (.Veputization being made at the request and risk of the plaintiff. , _ _•_~ __ ~, • 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. 0/C Ct~nbarland Please mail return of service to C(~nberland County Sheriff. Thank you. ADVANCE FEE PD BY CUMBERLAND COUN NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sherrH levying upon or attaching any property under within wnt may leave same without a watchman, In custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plainfiH herein for any loss, desWdion, or removal of any property before shenfrs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY /ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 1 t DATE FILED JOSPEH H~=TCHTNGS OF MCSHANE&HTTCHINGS LLC ( 717-657-390a 7/5/07 12. SEND NOTICI: OF SERVICE COPY TO NAME AND area must be completed R notice is to be marled). CUMBERLAND COUNTY SHERIFF 1 COURTHOUSE SQUARE CARLISLE PA 17013 SPACE IOW FOR USE OF THE SEFRFF - DO NOT WRITE ~10W THS L>>T~ 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED t5. EzpirationlHeasing Oate or oomplamt as indicated above. L T M M C G I L L 7/ 10 / 0 7 8/ 4/ 0 7 16. HOW SERVED: PERSONAL ( RESIDENCE ( POSTED ( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O I hereby certiy and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks bebw.) 18. ND TITLE INDIVIDUAL SERVED /LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Detendanq 19. D to of ervice 20 Time or Service "`~' i C/~ ~ ~ wtr: L 5w-t~'l. 2 07 Z 21. ATa'EMPTSI Oale I Time I Miles ~ Mt. { Oate I Time ~ Miles I Int. { Oate I Time I Miles I Int. { Date I Time J Miles ~ Int. { Oa1e ~ Time Miles ~ Int. { Date ~ Time I Miles I Int 22. 23. Advance Costs 21 Service Costs 25 N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 3t Swchg. 32 Td. Costs 33 Costs Oue etund Check No 100.00 •00 d ~. (~(} 7 76 ]4. Foraiyn CourKy Costs 35. Advance Costs 36. Service Costs 37. Notary Cert. 38. Mileage/Poslage/Not Found 39. Total Costs 40 Costs Oue or Refund A YVERS at.AFFIRM n E D a d s 7to ber a me this ubscrib~eid aa_ Signature of ~ a TE , . ~ r l ~ ~~ ~ 42 day ai~llasa~x~. =~-Y1 ~~. P DeP. Sherd( ~ D NOTARIAL SEAL P~~~'NO RY as. SignatureotY County Shenff ~ iyyL a .OAT LISA L. BOVVA,".atv, NOTARY PUBLIC / 2 5 /0 7 `;'ORK COUNTY CITY O!= YUi2{ _ , ~IOP. ~-~r'!~'RS AUG. 12, 2009 ~~C CO(vl" aB «egn 49 GATE r • MY County ShenR 50. I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE I St. UAl t KtGtIVtU OF AUTHORIZED ISSUING AUTHORITY AND TITLE t. WHITE - Isswng AWtoriry 2. PINK -Attorney 3. CANARY • SheriRs Office 4. BLUE - St-erdrs Olrice `r .:°~. ~. ~ ':~b~ A A tl+ 9 V ~ Y V ( ~ hS ~ 4 W~ ~~ ~~~ 1~0~ 3~1~~H~S 3lil ~A 3~1.~,.3Q -., w ..a Q3~k~~~3~3~ w;~..;,i F: \FILES\Travelers3090\Curtent\864\3090.864. pra 1 ,,,. tl Created: 9/20/04 0:06PM Revised: 8/13/07 5:04PM George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant ADEEB RASHEED, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v NO. 07-4046 CIVIL ACTION -LAW JAMIE SMITH, Defendant. JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON LAW OFFICES on behalf of Defendant in the above matter and issue a rule upon the Plaintiff to file a Complaint within twenty (20) days from service thereof or suffer judgment of non pros. Defendant hereby demands a twelve juror jury trial in the above captioned action. By Dated: August 14, 2007 RULE AND NOW, this /Y ~ day of , 2007, a Rule is issued upon the Plaintiff to file a Complaint within twenty (20) days from service hereof. s rothonotary ~~ i.L. ivv. ~+yais 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant +.., . Y CERTIFICATE OF SERVICE I, Melissa A. 5cholly, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph L. Hitchings, Esquire Mc5HANE & HITCHINGS, LLC 4807 Jonestown Road Suite 148 Harrisburg, PA 17109 MARTSON LAW OFFICES By I ~- _ Melissa A. Scholly Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 14, 2007 y ~ r~=, r ,., c~ ~ ,,.,,,, '"(J !~C~ ___ .~ -~, f -7 ~* ~. ~.~ w,.. . 1. d ~~~ M~ r R A~3 / ~ r i ADEEB RASHEED, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :DOCKET NO.: 07-4046 CIVIL ACTION -LAW JAMIE SMITH, Defendant :JURY TRIAL DEMANDED To: Jamie Smith NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment maybe 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING AN ATTONEY. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFOMRAITON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. LAWYER REFERRAL SERVICE 4~' Floor, Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 AVISO LISTED HA SIDO DEMANDANO/A EN CORTE. Si usted desea defenderse de las demandas que presentan mas adelante en las siguientes paginas, debe tomar accibn dentro de los proximos vietne (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente or por medio de un abogado una compazencencia escrita y radicando en la Corte por escrito sus defenses de, y objecciones a, law demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomaz accibn como se describe anteriormente, el caso puede procedaz sin usted y un fallo paz cualquier soma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o poriedad u otros derechos imporantes paza usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTAT OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. LAWYER REFERRAL SERVICE 4~' Floor, Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 ADEEB F. RASHEED :COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. . DOCKET NO.: 07-4046 JAMIE SMITH, :CIVIL ACTION -LAW 3ury Trial Demanded Defendant COMPLAINT AND NOW, this / D~ day of September 2007, comes the Plaintiff, Adeeb F. Rasheed, by and through his attorney's, McShane & Hitchings, LLC, and Joseph L. Hitchings, Esquire, and avers in support in his Complaint against the Defendant as follows: 1. Plaintiff, Adeeb F. Rasheed, is an adult individual residing at 1411 S. 12`~ Street, Harrisburg, Dauphin County, Pennsylvania 17109. 2. Defendant, Jamie Smith is an adult individual with a last known address of 270 Spanglers Mill Road, New Cumberland, Cumberland County, Pennsylvania 17070. 3. On July 5, 2005, at approximately 4:36 p.m., Plaintiff was operating a 1995 Plymouth Van, bearing Pennsylvania registration FPP 1109, traveling in an eastbound direction on Cedar Cliff Drive in Lower Allen Township, Cumberland County, Pennsylvania. 4. At said time and place, Defendant, Jamie Smith, was operating a 1993 Nissan 240 SX, bearing registration GCH5614, in a westbound direction on Cedar Cliff Drive in Lower Allen Township, Cumberland County, Pennsylvania. 5. Cedar Cliff Drive is a two-lane roadway with aone-way of travel in each direction. 6. At said time and place, the vehicle being operated by Defendant, Jamie Smith, crossed the centerline into and through the eastbound lane of travel and into the guardrail on the eastbound lane of travel and in front of the vehicle driven by Plaintiff, causing vehicles to collide. Count I -Negligence 7. Paragraphs one through six hereof are incorporated by reference as if the same of them were fully set forth at length herein. 8. The collision of the Defendant's vehicle with the Plaintiff's vehicle was a direct and proximate result of the careless and negligent conduct of the Defendant, including but not limited to: a. Operating a vehicle in a reckless manner; b. Failing to maintain a proper lookout; c. Failing to have his vehicle under control; d. .Failing to stop his vehicle before colliding with the vehicle being operated by Plaintiff; e. Traveling at an excessive rate of speed; f. Failing to stay in his lane of travel; g. Crossing over and into the lane of travel of the Plaintiff s vehicle, and; h. Failing to comply with the provisions of the Pennsylvania Motor Vehicle Code relating to the operation of motor vehicles, specifically as they relate to the aforesaid acts of negligence. 4. As a direct and approximate result of the careless and negligent conduct of Defendant, Plaintiff sustained the following injuries and/or aggravations ofpre-existing conditions, some are all of which may be permanent: a. injury to his cervical spine, left ankle, and lumbar spine; b. right shoulder and left thumb injury; c. vision difficulties; d. headaches; and e. general pain and suffering. 10. As a direct and approximate result of the careless and negligent conduct of the Defendant, and the injuries suffered in the accident, the Plaintiff was unable to work for a period of time resulting in the loss of wages. 11. As a result of the accident and injuries sustained therein, Plaintiffhas suffered serious and permanent injury, which required treatment, including surgery, for which he has incurred medical bills and expenses and may require further medical treatment in the future. 12. As a result of the accident and injuries sustained therein, Plaintiff has suffered an interruption of his daily habits and pursuits to his detriment and loss. 13. All injuries and damages as set forth herein, suffered by Plaintiff, Adeeb Rasheed, were proximately caused by the negligence of the Defendant. WHEREFORE, Plaintiff, Adeeb Rasheed, demands judgment against the Defendant, Jamie Smith, in an amount in excess of twenty-five thousand ($25,000.00) dollars, plus costs, interest, and delay damages, if applicable. Respectfully submitted, McShane & Hatchings, LLC Joseph itchin squire Attorney ID No.: 655 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Attorney for Plaintiff VERIFICATION I, Adeeb F. Rasheed, verify that the statements made in this Complaint are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date Adeeb F. Rasheed r, ADEEB F. RASHEED :COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO.: 07-4046 JAMIE SMITH, :CIVIL ACTION -Law Jury Trial Demanded Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing Complaint upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service via First Class US Postal Services George B. Faller, Jr., Esquire, Marston Law Offices 10 East High Street Carlisle, PA 17013 Dated: September ~, 2007 h L. Hi things, E ' e Attorney ID No.: 6555 4807 Jonestown Road, S to 148 Harrisburg, PA 17109 Telephone: (717) 657-3900 Attorney for Plaintiff ~ ts.~ "b :~ . ._.. ~ ~~ A F:(FILES\Clirnis\Travekrs30901Currrnt1864\3090.864, ans 1 /tde Created: 9/20/04 0:06PM Revised: 9/21 /07 10:25AM George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant ADEEB RASHEED, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4046 CIVIL ACTION -LAW JAMIE SMITH, . Defendant. JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT TO: ADEEB RASHEED, Plaintiff, and his attorney, JOSEPH L. HITCHINGS, ESQUIRE YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAYBE ENTERED AGAINST YOU. AND NOW, comes the Defendant, Jamie Smith, by and through his attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby responds to Plaintiff's Complaint as follows: 1. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments in this paragraph. 2-6. Admitted. COUNT I -NEGLIGENCE 7. The averments of paragraphs 1 through 6 hereof are incorporated by reference. 8-13. Denied pursuant to Pa. R.C.P. 1029 (e). WHEREFORE, Defendant demands judgment in his favor and dismissal of Plaintiff s Complaint with prejudice. i ~ NEW MATTER 14. The averments of paragraphs 1 through 13 of this Answer are incorporated herein by reference. 15. Plaintiff s recovery is barred or reduced by the Pennsylvania Motor V ehicle Financial Responsibility Law as amended. 16. Plaintiff s claim is barred or reduced to the extent that Plaintiff is bound by the limited tort option and did not sustain a serious injury. WHEREFORE, Defendant demands judgment in his favor and dismissal of Plaintiff's Complaint with prejudice. MARTSON LAW OFFICES Date: ~ ~(~~ 2(~pJ 7 By ..... .b...~.. ~ ...... ., ...., 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant .-. J1 ` VERIFICATION The foregoing Answer with New Matter is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. G J ie Smith F:\FILES1Clienis\Travelers3090\Curtrnt\86417090.864. ans I .~ CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Answer with New Matter was served this date by depositing same in the .Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph L. Hitchings, Esquire McSHANE & HITCHINGS, LLC 4807 Jonestown Road Suite 148 Harrisburg, PA 17109 MARTSON LAW OFFICES B is D. Eckenroad Ten East High Street Carlisle, PA 17013 T (717) 243-3341 Dated: ~',~~I !j/`Pi(, ~ ~0 ~ ~ 7 C? cr`'-s C7 ~- ~ -n t Ir ~,, ~ , _'r~ - i ~~ f V f , ~~ ~ r " ~ 4"~ ~_~ z M -~-~ ... , 'rt3 ~ .t A7 ri ~,~ ~ ~ ....! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RASHEED Vs. NO. 074046 SMITH CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR., ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which ` the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 07/10/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ~~~ i::'° ATTORNEY FOR DEFENDANT ~~:`4.. IBQIIIAI$8 880IILa SZ ~1DDU888D TO: MEDICAL LSGAL REPRODIICTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 By: Jamie Kendorski File #: M353526 CC~MAr~IQr~II,TE OF Pr3dZSYLVAN7A ~Ol~l'Y OF Q~RLAi~~ RASHEED Vs . Fi le NO. 074046 SMITH ~JBPOENA TO PRODUCE DOCIR'ENTS OR TH I NOS FOR DISOO'VERY PURSUANT TO RULE 4009 22 LOWER ALLEN TOWNSHIP, 1993 RUNNEL AVE, CAMP HILL PA 17011 TO: ATTN: CUSTODIAN OF RECORDS (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 o~~hing~,~,, __ ~+'~ A 1 at . ___ M1~DICAL LBt3AL RLPRODIICTIONS,(~eS~,940 DISSTON ST. , PHILA. , PA You may deliver or mail legible oopies of the documents or produce things requested h~ this subpoena, together wit! the certificate of carpliance, to the party making this request at the ad~ess listed above. You have the right to seek in advance the rea~,onablE 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 thi. subpoena may seek a court orde~- oampe t l i ng you to camp l y with i t. TH 15 SIAPOENA WAS ! SSIIED AT THE REt~IJEST OF THE FOLLOW I NO PERSON NAME: GEORGE B FALLER JR, ESQ ADDRESS: ~ 0--~ ~~H ST TELEPHONE : 7 013 SUPREME OOURT I D# 215 - 3 3 5- 3 212 ATTORNEY FOR: 4 9813 DEFENDANT M353526-O1 DATE : ~_ Seal of the t (Eff. 7/9T) 6Y THE T: Prothonotary/C1 1 Division ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR: LOWER ALLEN TOWNSHIP **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODfAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ l NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or LOWER ALLEN TOWNSHIP CUMBERLAND M353526-01 * * * SIGN AND RETURN THIS PAGE * M ~ OjD R MEDICAL ~LE~AL REPRODUCTIONS, INC. ~Kain Oi)'ice 4940 Diaston Street Philadelphia, Pa. 19135 Phone: (215) 335-3212 Faz: (215) 338-2980 E-mail Address: kga a~ed/egcour Jefferson Bldg., Suite 926 1015 Chestnut Street Philadelphia, Pa 19107 L09/ER ALLEN TQ~1'NSHIP ORIGINAL POLICE REPORT AND POLICE FILE, INCLLTDINC~ BVT NOT LI1[ITED TO ANY ACCIDENT REPORT, ANY NOTES OF THE OFFICERS AND PRINTS OF PHOT0~3RAPH3 . POLICE 7-~3ENCY 21102 DISPATCH TI>N>8: 1636 ARRIVAL TI>!~E s 1641. INVESTI~iATORa PTL TONY CAr.ss,:nMi BltD~3S #1827 CORJNTY: 21 - iM[ITiFICIPALITY: 102 - LONER ALLEN TO>I~PhTSHIP CR1188 Di71TE : 7 / 5 / 05 oo~IVwrALTx o~ pna~tLVANrA aolu~rY of RASHEED Vs . File No. 074046 SMITH suBPOENA To P oocuhlENTS oR THINOS FOR D 15001/ERY PURSUANT TO R~JLE 4009.22 ERIE INS CO, PO BOX 2013, MECHANICSBURG PA 17055 TO: ATTN: CLAIMS DEPT (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 o~in~~ _._ MNDICAL L$C~AL RSPRODIICTIONS,(4ss4~40 DISSTON ST . , PSILA. , PA You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together with the certificate of ccxrpliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the rea^.onable cast 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 thi. subpoena may seek a court orde~• ~Pe 11 ing yov to oorrply with it. THIS SUBPOENA WAS (SSI~D AT THE REQUEST OF THE FOLLOWINQ PER90N: p{q~: GEORGE B FALLER JR, ESQ ADDRESS: ~p E HIGH ST 7013 TELEPHONE: SUPREME OOURT I D S 215 - 3 3 5- 3 212 ATTORNEY FOR : 4 9 81 ~ DEFENDANT BY THE HOUR?: M353526-02 GATE: Seal of the _~i wn ~Ic, Division Deputy (Eff . 7/9T ) ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR: ERIE INS CO FIRST PARTY BENEFITS FILE FOR POLICY #Q012230397 PERTAINING TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WII.L BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHEDHERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ) NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or ERIE INS CO CUMBERLAND M353526-02 * * * SIGN AND RETURN THlS PAGE OF PII~H~SYLVANIA QOUNl'Y OF Ct1~I~D RASHEED Vs . File No. SMITH 074046 SUBPOENA TO PRODUCE DOCt~ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL PA 17011 TO: ATTN: MEDICAL RECORDS DEPT (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 SEtEin~s: __ at MEDICAL LLR(3AL RLPRODIICTIONS,(6s~940 DI33TON ST. , PBILA. , PA ~~ You may deliver or mail legible copies of the docuriants or produce things requested h~ this subpoena, together with the certificate of ornp 1 i ace, to the party making th i request at the address listed above. You have the right to seek in advance the rea~,onabl~ cost of preoaring 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 thi subpoena may seek a court orde~~ comps 11 ing you to coup 1 y with it . THIS SUBPOENA WAS ISSUED AT T}f REQUEST OF THE Fq.LOW1NCi PERSON: Na"E: GEORGE B FALLER JR, ESQ Aa1RESS: _ _ , ~ ~ vI-61;~ ,S~ TEIFPHONE: CARLISLE, PA 17013 SUPREI"E OOI.JFiT i D ~# 215 - 3 3 5- 3 212 ATTORNEY FOR : 4 9 813 DEFENDANT M353526-03 GATE:~~~~ Seal of the t BY THE T: - Prothonotary/C1• , it Division Deputy (Eff. 7/9T) ADDENDUM TO S UBPOENA RASHEED VS. SMITH No. 074046 CUSTODIAN OF RECORDS FOR : HOLY SPIRIT HO5P Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or HOLY SPIRIT HOSP CUMBERLAND M353526-03 * * * SIGN AND RETURN THIS PAGE OF PII~ISYLVANIA ~OftTiR OF C[1rIDEEti~1PID RASHEED . Vs . File No. SMITH 074046 SUBPOENA TO PRODUCE DOCt~ENTS OR TH 1 t~OS FOR DISODVERY PURSUANT TO RULE 4009.22 MEMORIAL EYE INST, 4100 LINGLESTOWN RD, HARRISBURG PA 17110 TO: ATTN: MEDICAL RECORDS DEPT (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 thi s: SEE ~T -- at MEDICAL LEGAL REPR0DIICTI0N3,(4ss4)940 DISSTON ST., PBILA., PA You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together wit?~ the certificate of carp 1 i ace, to the party making th i request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or producing the things sought. ff you fail to produce the documents or (20) days after its service, the party cx:rtpelling you to oamply with it. things required by this subpoena within twenty serving thi. subpoena may seek a court orde~• THIS SlJ8P0ENA WAS ISSUED AT Ti-E REQUEST OF TFE FOLLOWING PERSON: NAhE: GEORGE B FALLER JR, ESQ ADDRESS : ___.. , ~~~--n~.~F S'£ 7013 TELFPFpNE: SIJPRET'E OOURT I D# 215 - 3 3 5- 3 212 ATTORNEY FOR : 4 9 81 ~ DEFENDANT M353526-04 GATE: Seal of the BY TIf ? : - ~, Prothonotary/C erlc, vil Division Deputy ADDENDUM TO S UBPOENA RASHEED Vs. SMITH No. 074046 CUSTODIAN OF RECORDS FOR : MEMORIAL EYE INST Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ~ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS f XRAYS have been destroyed Date Aut orize signature or MEMORIAL EYE INST CUMBERLAND M353526-04 * * * SIGN AND RETURN THIS PAGE * * * o~ v~xrA aocnar~ of cam RASHEED Vs . File No. 074046 SMITH SUBPOENA Tt~ PRODUCE DOCI~"ENTS OR TH 1 N0S FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: HEALTHSOUTH, 555 E CHOCOLATE AVE STE 100, HERSHEY PA 17033 {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 o~ings~,~~~ at -~-~- MBDICAL LgaAL R$PRODIICTION3,{6ss4}940 DISSTON ST., PBILA., PA You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together w i tl~ the cd^t i f i cate of carp 1 i ace, to the party making th i request at the address listed above. You have the right to seek in advance the rea~.onabl~ 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 thi, subpoena may seek a court orde:• comps 11 ing you to can,ply with it. THIS SlSPOENA WAS I SSUEO AT TFf RE(iIIEST OF THE FOLLOW i IVC3 PERSON NAI"E: _ GFOR B FALLER JR, ESQ ADDRESS: TELFPFiOiVE . ,-'PK~'7 013 51JP1~E OOURT I D# 215 - 3 3 5- 3 212 ATTORNEY FOR: 4 9813 DEFENDANT M353526-05 DATE: Seal of the t BY THE T: _ Protha~otary/C1 Division _ .. ,- Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR : HEALTHSOUTH ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WII.L BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO: I hereby certify 'as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ l NO DOCUMENTS AYAILABI..E: I hereby certify that a thorough search has been made-and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS { ) RECORDS / XRAYS have been destroyed Date Aut orize signature or HEALTHSOUTH CUMBERLAND M353526-05 * * * SIGN AND RETURN THIS PAGE * 0O1~~LTH OF pII~SYLVANIA ~[ET1R OF RASHEED Vs. SMITH File No. n~4n46 SUBPOENA TO PRODUCE DOGUt~ENTS OR TH I NC3S FOR DIS00'VERY PURSUANT TO RULE 4009.22 DR DAVID LONG, 4076 MARKET ST, CAMP HILL PA 17011 TO: (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 ADDENDUM T at _ ._ MEDICAL LEGAL RSPRODIICTIONS,(Ay~940 DISSTON ST., PBILA., PA You may deliver or mail legible copies of the documents yr produce things requested h~ this subpoena, together wit!1 the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the rearonabl~ cost of preparing the copies or producing the things sought. {f You fail to produce the documents or things required by this subpoena within twenty (20) days after its .service, the party serving thi, subpoena may seek a court orde~~ compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT TtE REQUEST OF T1~ FOLLOWING PERSON: NAIrE: ~F.nRC'F R FAT,T,FR JR, ESQ ADDRESS: TELFPHONE• CARLISLE, PA 17013 SUPREhE OOURT l D ~# 215 - 3 3 5- 3 212 ATTORNEY FOR:_ a g~i DEFENDANT M353526-06 DATE: _ Seal of the t BY THE T: Prothonotary/Clerk, C Division Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR : DR DAVID LONG ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN t ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. t ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search . has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX}: ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( )RECORDS / XRAYS have been destroyed Date Aut orize signature or DR DAVID LONG CUMBERLAND M353526-06 * * * SIGN AND RETURN THIS PAGE oo~a~.Te of ~sYLV~xrA ao~n~r of o RASHEED Vs. SMITH File NO. 074046 SUBPOENA TO PRODUCE DOCUhENTS OR THINGS FOR D1900VERY PURSUANT TD RULE 4009.22 HERITAGE DIAG CTR, PO BOX 359, CAMP HILL PA 17001 T0: (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doaments or things: SEE ATTACHED ADDENDUM -- at Y~~i >lI~DICAL LSf~AL RSPRODIICTIONS,(A~e3~940 DISSTON ST. , PBILA. , PA You may deliver or mail legible copies of the documents or produce things requested ~? this subpoena, together w i tl1 the certificate of carp 1 i ante , to the party making th i request at the address listed above. You have the right to seek in advance the rea.onabl~ cost of precaring 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 thi. subpoena may seek a court orde~- ocrrpe l l i ng you to cmp 1 y with it . THIS SI~POENA WAS ISSUED AT TFE REQUEST OF THE FOLLOWING PERSON: NAhE: fS'R'nRC'F R FAT,T.FR JR, ESQ ADDRESS: ~F CARLISLE, PA 17013 SUPREh£ OOURT I D# 215 - 3 3 5- 3 212 ATTORI~Y FOR : 4 4 a i ~ DEFENDANT M353526-07 GATE : ~1 ~~ Seal of the ~V r~ (Eff. 7/97) ADDENDUM TO SUBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR : HERITAGE DIAL CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or HERITAGE DIAG CTR CUMBERLAND M353526-07 * * * SIGN AND RETURN THIS PAGE OQNALTS or' ~snvANrA ao~n~r a~ ar~r~,r~ RASHEED ' Vs. SMITH F11e No. X74046 susP~oENa To PRODUCE ooa~rlEwTS oR TH FOR DISOOVERY PURSUANT TC RULE 4009.22 ~: DR EDWIN AQUINO, 845 SIR THOMAS CT STE 10, HARRISBURG PA 17109 (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 ADDEND -- at MEDICAL LE~3AL REPR0DIICTI0NS,(q~s~940 DISSTON ST. , PHILA. , PA You may deliver or mail legible copies of the documents or produce things requested ~~ this subpoena, together with the certificate of ccrtplia~ce, to the party making thi: request at the address listed above. You have the right to seek in advance she rea.onable cost of preparing the copies or producing the things sought. If you fail to produce the documents or (20) days after its service, the party oampeiling you to carply with it. things required by this subpoena within twenty serving this subpoena may seek a court orde~~ THIS SU6POENA WAS ISSUED AT THE REQUEST OF THE F0LLOWINC3 PERSON: NAhE: n~n~arF g EAr.T,F•R JR, ESQ . ADDRESS: T.ELFPFK3NE : CARLISLE , PA 17 013 SUPREhE OOl1FtT I D# 215 - 3 3 5- 3 212 ATTORNEY FOR : _ a qR i ~ DEFENDANT M353526-08 DATE: Seal of the t BY THE T: Protha~otary/Clerk, C1 Division Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA RASHEED Vs. SMITH No. 074046 CUSTODIAN OF RECORDS FOR : DR EDWIN AQUINO ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTII~ IED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify. as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ) NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING - ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or DR EDWIN AQUINO CUMBERLAND M353526-08 * * * SIGN AND RETURN TH1S PAGE OF ~'IId~SYLVANIA QOOIJiR OF Q~~D RASHEED . Vs . File No. SMITH 074046 SUBPOENA TO PRODUCE DOCUhENTS OR TH1NCaS FOR DISOONERY PURSUANT TO RULE 4009.22 TO: DR BERNARD ZELIGER, C/O ARLINGTON ORTHO, 805 SIR THOMAS CT HARRISBURG PA 17109 Name of Person or Enti Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fat lowing doaments orsings• __ at MEDICAL LEGAL REPRODIICTIONS,(Adss~940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together wi t!~ the certificate of oorrp l i ance, to the party making th i request at the address listed above. You have the right to seek in advance the rea.onabl~ cost of preoaring 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 saving thi, Subpoena may seek a court orde:- ~Pelling you to Damply with it. TH 1 S S118P0ENA WAS ISSUED AT T}f REGZUEST OF TFE FOLLOW I NO PERSON NAhE: GEORGE B FALLER JR, ESQ ADDRESS: _ ~0-E-#d.~6#~-ST TELEPHONE : 7 013 SUPRElrE OOURT I D# 215 - 3 3 5- 3 212 ATTORNEY FOR : 4 9 813 DEFENDANT M353526-09 DATE : `~~....~o~ ~_ Seal of the BY THS /Clerk,-CiYi.~lfivision (Eff. 7/97) ADDENDUM RASHEED Vs. SMITH TO S UBPOENA No. 074046 CUSTODIAN OF RECORDS FOR: DR BERNARD ZELIGER ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WII.L BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or DR BERNARD ZELIGER CUMBERLAND M353526-09 * * * SIGN AND RETURN THIS PAGE Casa o~ ~ra~snvANrA aaRrrY of arm RASHEED Vs. SMITH File No. 074046' SIJHPOENA TO PRODUCE DOCI~ENTS OR TH 1 NC~S FOR D1900~VERY PURSUANT TO RULE 4009.22 .f0: MORGANSTEIN REHAB ASSOCS, 845 SIR THOMAS CT STE 7, HARRISBURG PA 17109 (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 ADDENDUM at MEDICAL LEGAL REPRODIICTION3,(A'»bss1~940 DI3STON ST., PHILA., PA You mny deliver or mail legible copies of the documents or produce things requested ~y th i s subpoena, together wi tl~ the cart i f i cate of ccrtp l i ance, to the party making th i request at the address listed above. You have the right to seek in advance the rea^.onabl~ cost of preoaring 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 orde~- oarrpe 11 ing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: ~~ rF.C1RC`F R FAT~T~F.R JR, ESQ ADDRESS: TELEPHONE : CARLISLE , PA 17 013 SUPREME OOURT I D S 215 - 3 3 5- 3 212 ATTORNEY FOR: d 9R1~ DEFENDANT M353526-10 DATE: Seal of the t BY THE T: Prothonotary/Clerk, Civ ivision w /' Deputy (Eff. 7/97) r ~ ADDENDUM TO S UBPOENA RASHEED Vs, SMITH No. 074046 CUSTODIAN OF RECORDS FOR: MORGANSTEIN REHAB ASSOCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( } RECORDS / XRAYS have been destroyed Date Aut orize signature or MORGANSTEIN REHAB ASSOCS CUMBERLAND M353526-10 * * * SIGN AND RETURN THIS PAGE ~ C..- ~ :r c~ ~ ^: ^ ..S ~~~ ; ~" ~i"r Y~y`~1~ ..,c. ~ F:\FILES\CGents\Travelers3090\Curtent\864\3090.864.mot. compel • Created: 9/20/04 0:06PM Revised: 12/2/08 9:31AM 7837.158 George B. Faller, Jr., Esquire I.D. No. 49813 Jacob M. Theis, Esquire I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER. MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant ADEEB RASHEED, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4046 CIVIL ACTION -LAW JAMIE SMITH, Defendant. JURY TRIAL DEMANDED DEFENDANT'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND NOW, comes Defendant Jamie Smith, by and through her attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and moves this Honorable Court to compel Answers to Interrogatories directed to Plaintiff: This case arises from a motor vehicle accident that occurred on July 5, 2005, on Cedar Cliff Drive in Lower Allen Township, Cumberland County, Pennsylvania. 2. Defendant served Interrogatories and Request for Production of Documents on Plaintiffs' counsel on August 14, 2007. A copy of the Interrogatories are attached hereto as Exhibit «A „ 3. On June 12, 2008, Defendant's counsel wrote to Plaintiff's counsel pointing out that the Answers to Interrogatories and Responses to Request for Production of Documents were overdue, a copy of which is attached hereto as Exhibit "B." 4. On July 3, 2008, Plaintiffls counsel responded to Defendants Request for Production of Documents, but did not respond to Defendant's Interrogatories, claiming that he was waiting on additional information from his client in order to finalize the same. A copy of the cover letter included with Plaintiffls response to Defendant's Request for Production of Documents is attached hereto as Exhibit "C." 5. To date, no answers to Interrogatories have at any time been filed, nor has Defendant's counsel been advised as to when these maybe expected. 6. Plaintiff has violated Pa. R.Civ.P. 4006 by failing to respond to Defendant's Interrogatories. 7. No Judge has been assigned to this case, nor has any Judge made any ruling or disposition in this case. WHEREFORE, Defendant Jamie Smith requests this Honorable Court to set a deadline for Plaintiff to answer the Interrogatories or suffer sanctions. MARTSON LAW OFFICES By cob M. Th is, squire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: ~~c .~ , aw ~ Attorneys for Defendant George B. Faller, Jr., Esquire I.D. No. 49813 Jacob M. Theis, Esquire I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant ADEEB RASHEED, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v• NO. 07-4046 CIVIL ACTION -LAW JAMIE SMITH, Defendant. JURY TRIAL DEMANDED CERTIFICATE I, George B. Faller, Jr., Esquire, wrote to Plaintiff s counsel on June 12, 2008, requesting Plaintiff s discovery responses. Despite such request, Plaintiff s counsel has still not provided responses to Defendant's interrogatories. MARTSON LAW OFFICES a, Georg~`B. Faller, Jr., Esquir 10 East High Street ~ Carlisle, PA 17013 (717) 243-3341 Date: ~;~,~-t,Grc.~, ~~~ Attorneys for Defendant F \FII_ES.Traacltrsi 0U0~Rnrent`Rb11,0`i0 ~baintl l r..lttd 'i .U 0~1 ~'~ ~~P11 Rt~ircd S ItOi 31~PA4 George B. Faller, Jr., Esquire LD. No. 49813 vIARTSON DEARDORFF ~`'ILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant ADEEB RASHEED, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v• NO. 07-4046 : CIVIL ACTION -LAW JAMIE SMITH, Defendant. JURY TRIAL DEMANDED FIRST SET OF INTERROGATORIES OF DEFENDANT DIRECTED TO PLAINTIFF TO: ADEEB RASHEED, Plaintiff, and his attorney, JOSEPH L. HITCHINGS, ESQUIRE Enclosed are Interrogatories propounded by Defendant to be answered under oath by the aforesaid Plaintiff pursuant to Pa. R.C.P. No. 4005, within thirty (30) days from the date of service hereof. A copy of said Answers shall be served upon counsel for Defendant at the address below. These Interrogatories shall be deemed to be continuing Interrogatories and if, between the time of your Answers to said Interrogatories and the time of trial of this case, you or anyone acting in your behalf learn of any further information not contained in your said Answers, you shall promptly furnish said information to the undersigned by supplemental answers. As used herein, the words '`accident" or "occurrence" refer to the event or events described ;',' ~ in your Complaint and all related events and circumstances. The word "you" or "your" includes your `' attorneys, representatives, insurers, and all others purporting to act on your behalf. Unless otherwise specified, response to the following Interrogatories shall give the requested ~! ~-~ information for the period from July 5, 2005, to the present (hereinafter sometimes referred to as the ~~ "time period"). _ ,, EXHIBIT "A" It is hereby certified that a true and correct copy of these Interrogatories was mailed to counsel for the Plaintiff on this date by the undersigned. NiART~ON LAW OFFICES ,, ;' ' ~~ By ~~ ;~' ~%~'~ G`e rge B. Faller, Jr., Esf{ui'r~ I.D. No. 49813 +~ Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Date: August 14, 2007 Interrogatory :Vro. 1 For each health care practitioner Plaintiff has seen since the date of the accident (whether in coruiection with the injuries suffered in the accident or not), provide the identity of same, the purpose of seeing practitioner, the number and inclusive dates of each visit, a description of all medication recommended or prescribed, a description of any treatment received or recommended, a listing of any charges incurred and the identity of the person or entity paying same if not Plaintiffs. ANSWER: Interrogatory ti`o. 2 Identify any health care practitioner that you have seen for ten (10) years prior to the incident in question, including but not limited to, your family physician and give the name and address of each. ANSWER: Interrogatory No. 3 State whether, as a result of the said occurrence, you required any medical or vocational rehabilitation services; that is, services necessary to reduce disability and to restore the physical, psychological, social and vocational functions, including but not limited to: medical care, diagnostic and evaluation procedures, physical and occupational therapy, other necessary therapies, speech pathology and audiology, optometric services, nursing care under the supervision of a registered nurse, medical social services, vocational rehabilitation and training services, occupational licenses and tools, and transportation necessary to secure such services. If so, state fully: The names and addresses of all medical, rehabilitation facilities, hospitals and/or clinics at which you were examined or attended; the names and addresses of all individuals and physicians who attended or examined you; the date of each treatment; and a description of the treatment received. ANSWER: Interrogatory No. 4 State frilly all the injuries you claim to have suffered in or as a result of the said occurrence. AiV'S~VER: Interrogatory No. 5 As to the injuries claimed in Interrogatory No. 4, have you ever experienced or been treated for the same or similar condition? ANSWER: Interrogatory No. 6 State fully all elements of economic loss, and the dollar value thereof, that you claim to have suffered in or as a result of the said occurrence. As part of your answer, state specifically, any claims for loss of income, past, present and future, explain how that was computed, and provide the inclusive dates of all time lost from work, whether full time or part time. ANSw'ER: Interrogatory ~Io. 7 If you still suffer pain from any of your injuries and conditions resulting from the incident, state specifically the frequency and nature of the pain and the injuries or conditions from ~~~hich it emanates. AvS`VER: Interrogatory No. 8 What future reasonable and necessary professional medical treatment and~or care do you claim you will require as a result of the said occurrence? ANSWER: Interrogatory X10. 9 ~i~'as any investigation made of the accident or accident scene by you or by anyone acting on your behalf after the accident'? If so, then for each such investigation, kindly state further: (a) The date and time it was made; (b) The name, address and employment of the person who made it; (c) The date and present custodian of any report concerning the inspection or investigation; (d) The identity of all persons interviewed as part of the inspection or investigation; and (e) A description of any exhibits, including, but not limited to, photographs or drawings prepared in connection with the investigation or inspection. ANSWER: Interrogatory No. 10 Please identify each of your employers, state the inclusive dates of employment and your gross and net earnings on a weekly or monthly basis for the period beginning five years before the accident to and including the present. With respect to each such employment, please describe your job duties and responsibilities. ANSWER: Interrogatory No. 11 If you have tiled a Federal, State or Local Income Tax return for any of the five calendar years preceding the accident or any year since, please state whether copies were kept or subsequently obtained, and, if so, identify every person who has, or at any time had, a copy of same. Alternatively to an answer, you may attach complete copies of each return as filed, to include, without limitation, all schedules, W-2, 1099's and other attachments. ANSWER: Interrogatory ~'o. 12 State whether you have been unable to perform satisfactorily all duties required of you in your employment and all activities of daily living since the date of the said occurrence, indicating with particularity those duties and activities you were unable to perform and the names and addresses of all persons having knowledge of such, including your supervisors, fellow employees, family, friends and the like. State further the identity of any physician who has advised you concerning the limitations or duration of any such disability. ANSWER: Interrogatory :vo. 13 Please state the name and address of any insurer, auto or otherwise, which you believe provides coverage, whether first party, third party, primary, secondary, contingent worker's compensation or other, for any injury or loss arising out of the said accident, and state further the owner of the policy, the type of policy, a description of any claim made, the nature of the coverage, the limits of each coverage applicable, the nature and amounts of any benefits paid by any such insurer and a description of any claim that was denied in whole or in part, as well as the name, address, policy number and claim number for any claim arising out of the events described in the policy number(s) and claim number(s) for any claim arising out of the events described in the complaint. ANSWER: Interrogatory No. 14 Identify any medical expenses which you have incurred which have not been covered by a collateral source (i.e. first party medical coverage, worker's compensation, Blue Cross; Blue Shield, etc.). ANSWER: Interrogatory No. 15 Please identify each person you expect to call as an expert witness at trial and state the subject matter on which each person is expected to testify. ANS~~'ER: Interrogatory No. 16 As to each person identified in your answer to the preceding interrogatory, please state the substance of the facts and opinions to which he is expected to testify and the grounds for each opinion.* Signature of Expert *A report, personally signed by your expert, may be furnished in lieu of your answer to this interrogatory. If you elect to furnish reports in lieu of an answer, then please indicate in the space above the date of each such report and the persons by whom they were prepared. Interrogatory No. 17 Identify every person known to you who claims to have seen or heard any of the parties make any statement or statements pertaining to any of the events or happenings alleged in the pleadings. ANSV~'ER: Interrogatory No. 18 Identify every person known to you, who you believe may have knowledge concerning: (a) The happening of the accident; (b) Any fact or circumstance pertaining to the accident; or (c) The conditions at the scene at, or immediatelybefore or after, the time of the accident. ANSWER: Interrogatory No. 19 Have you, your attorney, or any representative of you or your company entered into or been a party to any releases, stipulations, understandings or agreements regarding your liability for the claims which have been made in this case? ANSWER: Interrogatory No. 20 Have you ever been an occupant of an automobile that was involved in a collision, other than the collision described in your Complaint? If so, please state: (a) the date and location of each collision; (b) the identity of all other occupants of all vehicles involved in the collision; (c) whether you were injured in the collision, and, if so, the nature and extent of your injuries; (d) whether a claim was made by you as a result of the collision, and, if so, the identity of the insurer and claims adjuster and location of the claims office of all insurers against whom any claim was made by you, whether as a first party or third party; (e) whether you were a party in any court action or arbitration arising out of the collision, and, if so, please state below the full caption, identity of all attorneys, and the present status of said court action or arbitration. ANSWER: Interrogatory No. 21 Have you ever been convicted or pled guilty to a crime? If so, list the court, the offense and the date of the conviction or guilty plea. ANSWER: Interrogatory No. 22 Have you ever, either prior to or after the accident, made a claim for a personal injury or worker's compensation? If so, describe the circumstances surrounding the claim including the name of the party against whom the claim was made and their insurance company. ANSWER: Interrogatory No. ?3 State your full name, any aliases, prior names, nicknames and your social security numbers and date of birth. ANS`W'ER: COi/1~1ON~VEALTH OF PENNSYLVANIA COL'~iTY OF SS. Adeeb Rasheed, being duly sworn according to law, depose and say that the facts set forth in the foregoing Answers to Interrogatories are true and correct. Adeeb Rasheed Sworn to and subscribed before me this day of _ , 2007 Notary Public CERTIFICATE OF SERVICE I, :~Zelissa A. Scholly, an authorized agent for :~Iartson Law Offices, hereby certify that a copy of the foregoing First Set of Interrogatories of Defendant directed to Plaintiff was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph L. Hitchings, Esquire McSHANE & HITCHINGS, LLC 4807 Jonestown Road Suite 148 Harrisburg, PA 17109 MARTSON LAW OFFICES `, Melissa A. Scholly Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 14, 2007 MARTSON LAW OFFICES In L~~r F~IG11 ~T~lei~l_T i. ~~ai.i>i l , PI~~s~i.~.~~1_v 1-111; 11 i.i~[~iiv~~I ~;-1`} 343-3i41 I~ v~.,iu[Le i,l' 243-1851) I~ n ;tai. r yt-~c~.v.martsonlau~.ct,m June 12, 2008 VIA FACSIMILE (790-6019, Joseph L. Hitchings, Esquire 5000 Ritter Road Mechanicsburg, PA 17055 RE: Adeeb Rasheed v. Jamie Smith No. 07-4046 -Cumberland County C.C.P. Our File No. 3090.864 Dear Joe: ,~:~~~Lv~i~: ~j,~t~~v 1)1~I~1:, EiLZ:~?~~?y~~ J~,r~ r,, P<,v~;.I ~ Ilj (alalsr~,rIIFR G. Rica L~.?\II .I. li. ~i''~.Rt?UK.!-l~ ~k VAIFI~.R ~.. API-Ait? ~~~,~,. ~~r~~~~ ~~j 1~,~~~~1-~.. ~11~1~,<~IK HI ivr~:k~' Y. C;u.ltt»~ [i.Crrt~ ~.:~L~z`~ i_i 1. ~~Ifl ~Kl-I B. ~'.ALLI~R ~H.~` ~is~.nao (~F R7I FIFO ~~I~IL IRIAI. tiPF..:IAl ISl' I had left several messages with your new office regarding the need to get the answers to the interrogatories and request for production of documents that were served on your client about ten months ago. If I do not get this discovery within the next ten days, we will have no alternative but to file a Motion to Compel. Very truly yours, MA13~T~ON LAW OFFICES I G~rge 1~. Fa~11er, Jr. GBF/nlm cc: Ms. Gloria J. Allsebrook (LOG5689) (via a-mail) F'FILES\Clirnts`Travelers3090\Currrnt ~ 864\3090.664.jh3 EXHIBIT "B" ~It3ktil ~rr~~v r1~~vlc:E. ~[>~ i)c~ ~~.:Y ~•r TRANSPAISSION VERIFICATION REPORT TIME 06f12f2008 17:07 NAME MARTSON LAW OFFICES FA>~ 717-243-1850 TEL 717-243-3341 SER.# BROM5J402857 DATE, TIME 06f12 17:06 FAX NO.fhlAME 7906019 DURATION 0 0 : 0 0:29 PAGE(S) 01 RESULT OK MODE FINE ECM MARTS4N DEART)~R.FF WILLIAMS QTTO GILRUY $z FALLER ~7ART'SON LAW OFFICES WILLIAM F. MARTSON JnHN B. FOWLER III DnNIEL I{: DEARDORT'C ~TIIOMAS J. WiLLL1MS* IVO V. c7rro III HUnERT X. GILRUY GRI.RGF„ Bi. FALLF.,R. JR.* DAVID A. ~I1'ZSLb10N5 CHRISTOPHER E. RICE JFivNirER I.. srxnRs SETFI T. MoSEeEY T"RUDY E. FitlLiNCeR I~,1T1E J. M~xWeLL 10 EAST HIGH STRfiF.,T I.ARI.iSi.fy PBNNSVI..VANI,~ 17013 TELEPHONE (717) 243-3341 k7ACSIMII.E (717) 243-1850 INTERNET wwwmartsorilaw.com June 12, 2008 VIA FACSIMILE f790~601,9~ Joseph L. Hitchings, Esquire 5000 Ritter Road Mechanicsburg, PA 17055 RE: Adeeb Rasheed v. Jamie Smith No. 07-4046 -Cumberland County C.C.P. Our File No. 3090:864 Dear Joe: "Boexu Cexrcrian CivtL Tas~u. Srecieusr I had left several messages with your new office regarding the need to get the answers to the interrogatories and request for production of documents that were served on your client about ten months ago. If I do not get this discovery within the next ten days, we will have no alternative but to file a Motion to Compel. Very truly yours, MA~T`~ON LAW OFFICES ti LA W OFFICE OF JOSEPH L. HITCHINGS ATTORNEYAND COUNSELOR AT LAW Rossmoyne Business Center 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Tel: (717) 458-8123 Fax: (717) 790-6019 Email: hitch67~ir~comcast.net George B. Faller, Jr., Esquire, Martson Law Offices 10 East High Street Carlisle, PA 17013 July 3, 2008 Re: Adeeb Rasheed v. Jamie Smith No.: 07-4046 Cumberland County Dear Attorney Faller: Enclosed please find the Plaintiff's Response to Request for Production of Documents along with the responsive documents. I am still waiting on some information from Mr. Rasheed in order to finalize the Answers to Interrogatories. As soon as I have the necessary information, will promptly forward those over to youu. Please note 1'll be out of the office from Friday July 4, 2008 until Monday July 14, 2008. Thank you for your attention to this matter. Cc: Adeeb Rasheed ery truly yours, "~ /'Joseph . Hitchin Esquire EXHIBIT "C" ,~ CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Answer with New Matter was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph L. Hitchings, Esquire McSHANE & HITCHINGS, LLC 4807 Jonestown Road Suite 148 Harrisburg, PA 17109 MARTSON LAW OFFICES y cia D. Eckenroad " Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: ~ ,~~~ ~~~ ~::~.- - ..c .~: cn }--- ._ ;~. 4 r.. a~ ~t '_~ ~a 5_ "Si E a, ~~ .. q' ~~ < R ~C~r Q ~ Z~~(J' George B. Faller, Jr., Esquire I.D. No. 49813 Jacob M. Theis, Esquire I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys far Defendant ADEEB RASHEED, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4046 CIVIL ACTION -LAW JAMIE SMITH, Defendant. JURY TRIAL DEMANDED ORDER AND NOW, this day of 008, upon consideration of Defendant's Motion to Compel Answers to Interrogatories, it is hereby ORDERED that Plaintiff shall answer Defendant's Interrogatories within twenty (20) days of the date of this Order. Failure to comply with the time period set forth in this Order may result in the imposition of sanctions including the preclusion of evidence and the imposition of attorne ' BY T, J. ~ ~~~~ ,~ r'-~rb .~ ~,do ~~ ~ ~ . P~ i,,ci~~ 1C~'' ~. ,., +~s ~~ ~a ~- ~~oaoaz t~~;~~s~.c~'~i ~° hzi~~ :~,~~~~-~-Q3~ 9v~bl"! IN TIC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RASHEED Vs. . NO. 074046 SMITH CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 12/15/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQIIIRIBS SHOIILD BL ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 File #: M358635 By: Christine Knight IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RASHEED Vs. SMITH I No. 074046 TO: JOSEPH HITCHINGS, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 11/21/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT IIQQIIIRI$3 SSOIILD BS ADDR$SS}3D TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Christine Knight Enc(s): Copy of subpoena(s) Counsel return card File #: M358635 C~TH of FENIl~ISYLVANIA COUIai'Y OF RASHEED Vs . File No. 074046 SMITH SUBPOENA TO PRODUCE DOCt~1ENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 HERSHEY MED CENTER, 500 UNIVERSITY DR, HERSHEY PA 17033 T0: _ nTTnT ~ MF1~T_CAL RECORDS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fo 11 ow i ng docurnents o~~i ng~ __ at _ 44~~ ----~- MEDICAL LEGAL RSPRODIICTIONS,(~ess)940 D .. •. --~ You may deliver or mail legible copies of the documents or produce things requested ~~ this subpoena, together wit! the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the rea.onabl~ 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 thi. subpoena may seek a court orde~- cxnpe 11 i ng you to carp 1 y with i t . THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOI.LOWINO PERSON: NAhE: GEORGE B FALLER JR, ESQ ADDRESS: _ In F, NTCN ST 7013 TELEPHONE: SUPREIrE COURT I D# 215 - 3 3 5- ATTORNEY FOR : 4 9 813 M358635-O1 DEFENDANT DATE : 7-~ .z y~ UU ~ Seal of the Court BY T1-E COURT : Prothonotary/ le k, Civil Division - qty (Eff. 7/97) RASHEED Vs. SMITH ADDENDUM TO SUBPOENA No. 074046 CUSTODIAN OF RECORDS FOR : HERSHEY MED CENTER Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physic therapy records, and any other information pertaining to: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN -COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO: I hereby certify as custodian o records that, to the best of my knowledge; information and belief all documents or things above mentioned have been pro [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sea has been made and that no record of the following documents been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date ut orize signa ure or HERSHEY MED CENTER CUMBERLAND M358635-O1 * * * SIGN AND RETURN THIS PAGE * * * ~Tx ol~ gEru~sYLVANrA RASHEED ODL]lal.'Y OF G[A~IAI~ID Vs . File No. SMITH 074046 SUBPOENA TO PRODUCE DOC1JhENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PRISM CTR FOR SPINE PAIN, 4310 LONDONDERRY RD, HARRISBURG PA 17109 TO: (Name of Person or Entity Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fo 11 owi ng documents ~E~i ng~ __ at _ _ MSDICAL LSOAL RSPRODIICTIONS,(~~i ess) 40 DISST . , • . +'~ You may deliver or mail legible copies of the documents or produce things requester! h~ this subpoena, together with the certificate of cortpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the reasonably 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 thi, subpoena may seek a court orde:- cx~rtpe 11 i ng you to carte 1 y with i t . THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAB; GEORGE B FALLER JR, ESQ ADDRESS: _ 10 E HTC~H ST 7013 TELEPHONE: 215-335-3212 SUPREhE OOURT ID # _ _ ATTORNEY FOR: 49813 DEFENDANT M358635-02 DATE : Y1.rYV-E~ at `F a. vy ~ Seal of the Court BY THE COURT: s Prothonotary/C 1 irk, Ci v i 1 D i v i s. i ory~-~ Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR : PRISM CTR FOR SPINE PAIN ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHE INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL AP RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian o records that, to the best of my knowledge: information and belief all documents or things above mentioned have been pro [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sea has been made and that no record of the following documents been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed ate ut orize signature or PRISM CTR FOR SPINE PAIN CUMBERLAND M358635-02 * * * SIGN AND RETURN THIS PAGE * * * OC~DNWEALTH OF FE>!IlSSYLVANIA OOi]IJi'Y OF RASHEED Vs. SMITH File No. 074046 SUBPOENA TO PRODUCE DOCt~ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4Q09.22 SUSQUEHANNA SURGERY CTR, PO BOX 6507, 805 SIR THOMAS CT TO: ~F.IS>3rmr pA 17112 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fot lowing doaments SEthing~ __ at _ MEDICAL LEGAL REPRODIICTIONS, (Addr,ess340 DI • . • ~ ----- You may deliver or mail legible copies of the documents or produce things requested 5y this subpoena, together with the certificate of crnpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onabl~ cost of preoaring 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 orde~- ornpe i l i ng you to camp l y with i t. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAhE: GEORGE B FALLER JR, ESQ ADDRESS: _ ~ 0 $ NTC,H ST 7013 TELEPHONE: SUPREhE OOURT I D# 215 - 3 3 5- 3 212 ATTORNEY FOR : 4 9 813 M358635-03 DEFENDANT DATE : /, u.uw y~l 02. ~ o2aU S' Seal of the Court BY THE ODURT: /S l ~.~,u~ ~ _ Protho/n~ota~ry/C1 Civi l Divis.ion~.' Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR: SUSQUEHANNA SURGERY CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHE INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL AP RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian o records that, to the best of my knowledge; information and belief all documents or things above mentioned have been pro [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sea has been made and that no record of the following documents been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed ate ut orize signature or SUSQUEHANNA SURGERY CTR CUMBERLAND M358635-03 * * * SIGN AND RETURN THIS PAGE * * COMMONWEALTH OF PIIaLSYLVI~INIA COUNTY OF QJMBIItIAND RASHEED Vs . File No. SMITH 074046 SUBPOENA TO PRODUCE DOCtlhENTS OR TH1 NC~S FOR DISOOVERY PURSUANT TO RULE 4009.22 T0: MAGNETIC IMAGING CTR, 4665 TRINDLE RD, MECHANICSBURG PA 17050 (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 ~~~nA~ ,,.~Trn,r __ at _ ~~iiCC MgDICAL LEGAL R$PRODIICTIONS.(Address) ~~ ~~ You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together wi t!~ the certificate of comp l i ante, to the party making th i request at the address listed above. You have the right to seek in advance the rea,onabl~ 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 thi^. subpoena may seek a court orde~- campelling you to onmply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FCLLCWINC~ PERSON: NAhE: GEORGE B FALLER JR, ESQ ADDRESS ~ _ i n F HIGH ST 7013 TELEPHONE: SUPREhE OOURT I D # 215 - 3 3 - ATTORNEY FOR: 4 98 13 DEFENDANT M358635-04 DATE : ~(,o-r,.rrz~,.~, _ 02 y a,071rP Seal of the Court BY THE COURT: Prothonotary/C1 k, Civil Divisiory~' Deputy (Eff . 7/97 ) ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHE INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL AP RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian o records that, to the best of my knowledge, information and .belief all documents or things above mentioned have been pro [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sea has been made and that no record of the following documents been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date u orize signature or MAGNETIC IMAGING CTR CUMBERLAND M358635-04 * * * SIGN AND RETURN THIS PAGE of FnuvsYLVANIA ~i]Ni'Y OF RASHEED Vs. File No. SMITH • 074046 SUBPOENA TO PRODUCE DOCIJhENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: Name of Person or Entity) CENTRAL PA REHAB SVCS, 805 SIR THOMAS CT, HARRISBURG PA 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents ~~in~~, ~,~. rrz+xmrra~r __ at ffiLDICAL L}3C3AL RgPR0DIICTIO • (Address) You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together wit! the certificate of carpliance, to the party making this request at the address listed above. You have the right to seek in advance the rea.onabl~ 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 •thi~ subpoena may seek a court order coupe 11 i ng You to oortp 1 y with i t . THIS SUBPOENA WAS ISSUEQ AT THE REQUEST OF THE FOLLOWING PERSON: NAhE: GEORGE B FALLER JR, ESQ ADDRESS ~ _ ~ 0 E HIGH ST T.T T[~T ~ riT ~ 7013 TELEPHONE: SUPREhE OOURT I D ~~# 215 - - ATTORNEY FOR : 4 9 813 DEFENDANT M358635-05 DATE : _~~~~JII,~`J~.I • 1 /ll. ~/ yi./U Seal of the Court s _ Prothonotary lark, Civil Division -~~ Deputy BY THE COURT: (Eff. 7/97) RASHEED Vs. SMITH ADDENDUM TO S UBPOENA No. 074046 CUSTODIAN OF RECORDS FOR : CENTRAL PA REHAB SVCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHE INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ABEED RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/0]./57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WII~L BE ACCEPTED IN LIEU OF YOUR PERSONAL AP RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian o records that, to the best of my knowledge: information and belief all documents or things above mentioned have been pro [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sea has been made and that no record of the following documents been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed ate Au orize signa ure or CENTRAL PA REHAB SVCS CUMBERLAND M358635-05 * * * SIGN AND RETURN THIS PAGE * * * RASHEED Vs. SMITH ooLTH of pnarsYLVANrA 0DUI!TI7 OF . File No. 074046 SUBPOENA TO PRODUCE DOCL~ENTS OR THINGS FOR DISO01/ERY PURSUANT TO RULE 4009.22 SCI CAMP HILL, PO BOX 8837, CAMP HILL PA 17001 TO: p1mmN~ PERSONNEL DEPARTMENT (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 c~~ir~~T T,r•t. ~nn~~ __ at _ ~-~~- MEDICAL LEGAL REPRODIIC ---~ (Address) You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together wit! the certificate of compliance, to the party making this request at the address listed above. You. have the right to seek in advance the rea.onabl~ cost of preparing the copies or producing the things sought. If You fail to produce the documents or (20) days after its service, the party cxrnpe 11 i ng You to pomp 1 y with i t . things required by this subpoena within twenty serving •thi, subpoena may seek a court orde~~ THIS SUBPOENA WAS ISSUED AT THI= REQUEST OF THE FOLLOWING PERSON: NAhE: GEORGE B FALLER JR, ESQ ADDRESS: - ~ Q E HIGH ST 7013 TELEPHONE: SUPREhE OOURT ID # 1 - - ATTORNEY FOR : 4 9 813 DEFENDANT M358635-06 DATE : .,~ .,,,,1~~ .Z ~ :trr~ ~ Seal of the Court BY THE COURT: s - t Prothonotary/C er Civil Division Deputy (Eff. 7/97) ADDENDUM TO S UBPOENA RASHEED Vs. No. 074046 SMITH CUSTODIAN OF RECORDS FOR: SCI CAMP HILL ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPOR AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING T NAME: ABEED RASHEED ADDRESS: 1411 S 1?TH ST IiARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL AP RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian o records that, to the best of my knowledge, information and belief all documents or things above mentioned have been pro [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough sea has been made and that no record of the following documents been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date ut orize signature or SCI CAMP HILL CUMBERLAND M358635-06 * * * SIGN AND RETURN THIS PAGE * * * ~~ ~' ~' i `..w~ ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY .. RASHEED Vs. NO. 074046 SMITH CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 01/26/09 ~-~-~-`. GEORGE B FALLER JR., ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT IMQIIIRISS S80IILD H$ ]1DDRSSSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 File #: M359693 By: Christine Knight IN TIC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RASHEED Vs. SMITH ~ No. 074046 TO: JOSEPH HITCHINGS, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no abjection is made the subpoena may be served. Date: 01/05/09 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQIIIRIES SHOIILD H$ ADDRESSED T0: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Christine Knight Enc(s): Copy of subpoena(s) Counsel return card File #: M359693 OF FII~II35YLVANIA . COUtdl'Y OF CIAI~ID RASHEED Vs . File No. SMITH . 074046 MSDICAL BYLLING RSQIISSTSD SUBPOENA TO PRODUE~ DOCIJhENT5 aR TH t NOS FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: PA NEUROSURG & NEUROSCIE, 4310 LONDONDERRY RD, HARRISBURG PA 17109 (Name of Person or Entity) Within twenty (20) days after s~-vice of this subpoena, you are ordered by the court to produce the following documents ~E~ i n$~ at _ _ ~-~~- 3KSDICAL LEGAL RSPRODIICTION3, (Ac~r'ess ~ ~ ~ ~ ~ V You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together with the certificate of crnpliance, to the party making thi~: request at the address listed above. You have the right to seek in advance the rea,onable 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 serv;ce, the party serving this subpoena may seek a court orde~~ otat~pe I l i ng you to onmp l y with i t. THlS SU6POENA WAS ISSUED AT THE REGiUEST OF THE FOl_LANINO PERSON: NAt"E: GEORGE B FALLER JR, ESQ AC~ORESS ~ ~ ~_ E HIGH ST 7013 TEI.FPI-IONE S11PREhE ODURT I D # 215 - 3 3 - ATTORNEY FOR : 4 9 813 DEFENDANT M359693-01 DATE : ~~ t~Q Seal of the Gburt BY THE QOURT: Prot tar iv' Division D~tY (Eff. 7/97) RASHEED Vs. SMITH ADDENDUM TO SUBPOENA Docket No. 074046 CUSTODIAN . OF RECORDS FOR: PA NEUROSURG & NEUROSCIE ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ADEEB RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: ~3:7~XXX7703 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WII.L BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS AREATTACSEDHERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTSAYAII.ABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (.CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or PA NEUROSURG & NEUROSCIE M359693 -01 * * * SIGN AND RETURN THIS PAGE * * * o~ pn~sYS,vAxrA oFa RASHEED ' Vs . Fl le NO. 074046 SMITH SUBPOENA TO PRODUCE DOCI~"ENT,STHINOSBxLLING RSQII$ST}3D FOR D I S00'VERY PURSUANT TO RSILE 4009.22 T0: DR RODNEY FRESHMAN, 845 SIR THOMAS CT STE 3, HARRISBURG PA 17109 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the followin9_docunents or thi s. SEE ~T - MEDICAL LLGAL RSPRODUCTIONS,(~ss4)940 DISSTON ST. , PBILA. , f~+~-- You may deliver or mail legible copies of the documents or produce things requested h~ this subpoena, together wit?~ the certificate of cortpliance, to the party making thi_ 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 docurients or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court orde~- campelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE RE(il>EST OF THE FOLLOWING PERSON: NAME: GEORGE B FALLER JR, ESQ ADDRESS: - ~ o ~ Hzru GT 7013 TELEPHONE: SUPREME OOURT f D ~#~ 215 - 3 3 5- 3 212 ATTORNEY FOR: 4 9813 DEFENDANT M359693-02 DATE: a Seal of th Court BY THE T: P of C1 , Civi 1 Division Deputy (Eff. 7/97) RASHEED Vs. SMITH ADDENDUM TO SUBPOENA Docket No. 074046 CUSTODIAN OF RECORDS FOR : DR RODNEY FRESHMAN ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATIOiv RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ADEEB RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN : ~:XXXX7703 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN. - COMPLETE AND RETURN [ ] RECORDS AREATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE; I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECR THE APPROPRIATE BOX): ( ).RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or DR RODNEY FRESHMAN M359693-02 * * * SIGN AND RETURN THIS PAGE * ~~ '~ ~; .'- --r~ : _, r-, • ~~ , ~7~i t r~ ~a 1 ,~_ :~: IN 1'HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY .~ ADDEB RASHEED Vs. . NO. 07-4046 JAMIE SMITH CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena (s) . Date: 05/07/09 File #: M362769 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT I1~QIII~LI88 SHOIILD BS ADDRBSS$D TO s MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 By: Christine Knight '- IN 1'HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY .~ ADDEB RASHEED - Vs . JAMIE SMITH TO: JOSEPH HITCHINGS, ESQ (PLAINTIFF) No. 07-4046 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 04/16/09 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT II~QIIIRIES SHOIILD BB ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Christine Knight Encfs): Copy of subpoena(s) Counsel return card File.#: ffi362769 w Og PENIl~LSYLVANIA .. OOWTIR OF ADDEB R.ASHEED Vs . File No. 07-4046 JAMIE SMITH MEDICAL BILLING REQIIESTED SUBPOENA TO PRODUCE DOCUrENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 WILLS EYE HOSP, 840 WALNUT ST, PHILA PA 19107 T0: AmmN~ MEDICAL RECORDS DEPT (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 ~Ei~ing~; _ at _ __ MEDICAL LEGAL REPRODIICTIONS, INNC~, ~~F •• •• (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together wit! the certificate of compliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea^..onable 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 orde~• compelling you to cartely with it. THiS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Nom; GEORGE B FALLER JR, ESQ ADDRESS: i n E HIGH ST 7013 TELEPHONE: 215-3 - SUPREhE OOIJFtT I D # _ ATTORNEY FOR : 4 9 813 DEFENDANT M362769-01 DATE : 3 ~f3~ '~ S 1 of the Court BY THE COURT. Pro 1 ,Civil Division Deputy (Eff. 7/97) ADDEB RASHEED Vs. JAMIE SMITH ADDENDUM TO S UBPOENA No. 07-4046 CUSTODIAN OF RECORDS FOR : WILLS EYE HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: ADEEB RASHEED ADDRESS: 1411 S 12TH ST HARRISBURG PA DATE OF BIRTH: 07/01/57 SSAN: XXXXX7703 MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN -COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut orize signature or WILLS EYE HOSP CUMBERLAND M362769-01 * * * SIGN AND RETURN THIS PAGE * * 4F ?~-~E ~~7~ nti~;TARY _ ZQOg na r i i ~~~ 3: ~ s CU~~1 ~. ,r ~, ~;;~,'VrY F~i'~tvS'~~.4~'V~~ ADEEB F. RASHEED :COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO.: 07-4046 JAMIE SMITH, :CIVIL ACTION -LAW JURY TRIAL DEMANDED Defendant PRAECIPE TO SETTLE AND DISCONTINUE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please mark the above captioned action settled and discontinued with prejudice. Respectfully Submitted. Date: 0 ~t w Office of Joseph L. Hitchings _-~~ ~Y r . ----.- . . ,F~ph L. tc in~~'s, Esqui Attorney I.D.# 655 t 5000 Ritter Road, Suite 202- Rossmoyne Business Center Mechanicsburg, Pennsylvania 170.55 Telephone: (717) 4~8-8123 Fax: (717)790-6019 Attorney for Plaintiff ~l`~~ ~' _ i~ I F"q ~ .,, .. .-