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HomeMy WebLinkAbout01-6198HAYT, HAYT & LANDAU BY: ARTHUR LASHIN IDENTIFICATION NE) 23425 SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106-2509 (215) 928-1400 ATTORNEY FOR PLAINTIFF FORD MOTOR CREDIT COMPANY One American Road Dearborfl, Michigan 48122 vs. ADAM WALKER 1607 Matthew Road Camp Hill, Pennsylvania and FAYE L. WALKER 515 Maple Avenue Marysville, Pennsylvania 17011 17053 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION TERM, CIVIL ACTION "NOTICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania i'7013' (717) 249-3166 "AVISO CML ACTION 1. Plaintiff, Ford Motor Credit Company, is a corporation duly organized and existing under the laws of the State of Delaware, and authorized to do business in the Commonwealth of Pennsylvania, with offices located at One American Road, Dearborn, Michigan 48122. 2. Defendant(s) Adam Walker and Faye L. Walker is/are individual(s) residing at the address(es) contained in the caption of this case. 3. On or about March 24, 2000, Defendant(s) (lessee) entered into a written Automobile Net (Closed End) Lease (hereinafter called the Lease) to lease a '¥ehicle" from a dealer (lessor) according to the terms, prices and conditions contained within the aforesaid Lease, a true and correct copy of said Lease being attached hereto, made a part hereof, and marked Plaintiffs Exhibit "A". 4. "Lessor" subsequently assigned the aforesaid Lease to Plaintiff, Ford Motor Credit Company. 5. Subsequently, Defendant(s) did default upon the aforesaid Lease by failing to make timely installment payment to Plaintiff and in accordance therewith the entire remaining balance became due and payable immediately. 6. The aforesaid Lease further provides that in the event of default, Plaintiff may repossess the '¥ehicle" and sell same in accord with the terms of the aforesaid Lease. 7. The aforesaid Lease further provides that lessee shall be liable for all costs and expenses, including reasonable attorney's fees, incurred by Plaintiff in enforcing the Lease. 8. As a consequence of the foregoing, there is currently due and owing to Plaintiff by the Defendant(s) the following sums: SCHEDULED PAYOFF $26,508.71 LESS: Sale Proceeds 16,400.00 Rental Security .00 Credit Life Insurance Premium Refund .00 Accident & Health Insurance Premium Refund .00 Finance Charge Refund .00 Extension Fee Refund .00 ADD: Past Due Payments 1,383.63 Unpaid Late Charges 103.77 Repossession Expense 458.50 Balance Owing $12,054.61 Customer Payments Received After Establishment of Deficiency .00 SUB TOTAL Interest Plus Attorney's fees at 20% TOTAL DUE $12,054.61 421.91 2,495.30 $14,971.82 9. Despite repeated demand by Plaintiff, Defendant(s) has/have failed and refused to pay the aforesaid sum. WHEREFORE, Plaintiff demands that judgment be entered against Defendant(s) in favor of Plaintiff in the amount of $14,971.82 together with interest and costs. HAYT, HAYT &~ By: Arthur Lashin, Esquire Attorney for Plaintiff STATE OF ARIZONA COUNTY OF MARICOPA AFFIDAVIT ~~ , being duly sworn according to law, deposes and says that he/she is ~i~. ~ for Ford Motor Credit Ccunpany, and that he/she is duly authorized to take this Affidavit on behalf of Ford Motor Credit Come, any, and that the facts contained in the attached pleading are true and correct to the best of his/her information, knowledge and belief. Sworn to and subscribed before me this ]~ day of * 0~ , 2001 N~ary ~ SHERIFF'S RETURN - CASE NO: 2001-06198 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERIJ~ND FORD MOTOR CREDIT COMPANY VS WALKER ADAM ET AL REGULAR SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WALKER ADAM the DEFENDANT at 1316:00 HOURS, at 1607 MATTHEW ROAD CAMP HILL, PA 17011 BONNIE WALKER, MOTHER a true and attested copy of on the 31st day of October 2001 by handing to COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 37.75 Sworn and Subscribed to before me this ~3 ~ day of ~ J~o ! A.D. ~z~othonotary So Answers: R. Thomas Kline ll/07/200i HAYT HAYT & LANDAU Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2001-06198 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS WALKER ADAM ET AL OUT OF COUNTY R. Thomas Kline duly sworn according to law, says, that he made a diligent and inquiry for the within named DEFENDANT , to wit: WALKER FAYE L Sheriff or Deputy Sheriff who being search and but was unable to locate Her in his bailiwick. deputized the sheriff of PERRY County, serve the within COMPLAINT & NOTICE He therefore Pennsylvania, to On November 7th , 2001 this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep Perry Co 6.00 9.00 10.00 47.60 .00 72.60 11/07/2001 HAYT HAYT & LANDAU Sheriff of Cumberland County Sworn and subscribed to before me this 73~ day of~-~ .2c'~ / A.D. I / Prothonotary' ' In The Court of Common Pleas of Cumberland County, Pennsylvania Ford Motor Credit Company VS. Adam Walker et al SERVE: Faye L. Walker No. 01 6198 civil NOW, October 30 ., 2001 ., I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Now, within upon November 2, ,20 Notice and Complaint Faye L. Walker Affidavit of Service ol ,at lo:ooo'clock g M. servedthe at 515 Maple Ave. Marys~{lle, Pa. 17053 by handingto Lloyd Walker, Def. husband True & Attested copy of the original Notice & Complaint and made known to Him the contents thereof. So allswers~  .~s C. Wilson Depu~ Sheriffof Perry County, PA Sworn and subscribed before me this ~,~c~ day of/~t~_~, 20..0/ COSTS SERVICE 18.00 $ MILEAGE ~ 7_ ~ 0 AFFIDAVIT 2 _ 00 47.60 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Ol~.lglN ~.k~ CIVIL DIVISION Ot~iGIN.~L' FORD MOTOR CREDIT COMPANY VS. ADAM WALKER and FAYE L. WALKER NUMBER: 01-6198 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGEs TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against the Defendant(s) Adam Walker and Faye L. Walker for failure to answer Plaintiffs Complaint, endorsed with twenty (20) day notice to plead, served upon Defendant(s) on October 31,2001 and November 2, 2001 and assess damages as follows: Unpaid Balance Plus Interest Late Charges Plus Attorney's Fees Less Credits, if any TOTAL DUE: $ 12,054.61 421.91 .00 2,495.30 .00 $14,971.82 Pursuant to PaR. C.P. 237.1, I hereby certify that notice to file this Praecipe was mailed to the above named Defendant(s) and the Attorney of Record (if applic~ember 27, 2001 and copy/copies of Same is/are attached hereto. ARTHUR LASHIN, ESQUIRE #23425 Attorney For Plaintiff HAYT, HAYT & LANDAU 400 Market Street 6th Floor Philadelphia, Pennsylvania 19106 (215) 928-1400 COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE FORD MOTOR CREDIT COMPANY vs. ADAM WALKER STATE OF PENNSYLVANIA COUNTY OF ~ILA~I~LPHi'A ' Arthur Lashin.'~ being duly sworn according to Law, deposes.and sayS:thai:he represents the Plaintiff in the above ~ntitled case; that heis authorized to make this Affidavit on behalf of the Plaintiff; and that the above named Defendant(s) is (are) 18+ years of age; the address of Defendant(s) is 1607 Matthew Road, Camp Hill, Pennsylvania 17011 Occupation of Defendant(s) is unknown; and the Defendant(s),is (are) not in the Military Service of the United States nor any State or Territory thereof or its Allies as defined in the Soldiers' and the Sailors' Civil Relief Act of 1940 and amendments thereto. ~DAU~ HAYT, HAYT AND ATTORNEY FOR PLAINTIFF Prothonotary Sworn to and subscribed before __me this 7th day of December -'~.~ ~ COURT OF COMMON PLEAS AFFIDAVIT OF NON-M/LITARY SERVICE FORD MOTOR CREDIT COMPA/~f vs. FAYE L. WALKER STATE OF PENNSYLVANIA COUNTY OF ~LApSL~iA ' Arthur Lashin~ i being dUly sworn according to Law, deposesand says ~that:he represents the Plaintiff in the above entitled case; that he is authorized to make this Affidavit on behalf of the Plaintiff; and that the above named Defendant(s) is (are) 18+ years of age; the address of Defendant(s) is 515 Maple Avenue, Marsville, Pennsylvania 17053 Occupation of Defendant(s) is unknown; and the Defendant(s),is (are) not in the Military Service of the United States, nor any State or Territory thereof or its Allies as defined in the Soldiers' and the Sailors' Civil Relief Actof 1940 and amendments thereto. I~5~/ HAYT, HAYT AND ATTORNEY FOR PLAINTIFF Prothonotary Sworn to and subscribed before me this 7th day of December 20 01 A.D Shad Deana Outen, Notary Public Philadelphia, mhilads]phia County My Commissio~ E×p]res Jun;* 27, 2002 HAYT, HAY'J' & LANDAU mXT~q FLOC~ 23425 400 MAFIKET STREET PHJLADI=I laI'IIA, PA lS106-250S ¢215) ~B-140~ FORD MOTOR CREDIT COMPANY One American Road Dearborn, Michigan 49122 VS'* ADAM WALKER 1607 Matthew Road Camp Hill, Pennsylvania 17011 ATTORNEYFORPLAiNTiFF DATE: NOVEMBER 27 2001 CUMBERLAND COUNTY COURT OF COMMON ?ZE/I$ CIVIL DIVISION TERM. No.~ 01-6198 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAUL, PURSUANT TO PA.R.C.P. 237.! You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the coum your defenses or objections to the claims set forth against you. Unless you act within ten days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important fights. You Should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to f'md out where you can get legal help: Court Administrator Cumberland County Courthouse Carlise, PA 17013 (717) 240-6200 ~kRTHUR LASI:IIN, ESQUIRE, #23425 HAYT, HAYT & LANDAU SIXTH FLOOR 23425 4O0 MARKET STREET PHILADELPHIA, PA 19106-250g (2'15) 928-1400 FORD MOTOR CREDIT COMPANY One American Road Dearborn, Michigan 48122 VS. FAYE L. WALKER 515 Maple Avenue Marysville, Pennsylvania 17053 ATTORNEYFORPLAiNTiFF DATE:__N~ooz CUMBERLAND COUNTY COURT OF COMMON PLEAs CIVIL D;FI$;ON TERM, 01-6198 CIVIL TERM NOTICE OF INTENTION .TO TAKE DEFA_ULT PURSUANT. TO P~A.,.R.C.p. ~37,! You arc in default because you have failed to enter a written appearance personally or ab~Ya~ay2m_e~Y ~ file in writing w. ith the court your defenses or o' ' ~ -m you. unless you act w~thin ten days om th, ~-- ~ b.j.ect~o .ns to the clamls set forth _ fr _. -- uate or this notice, a judgment may be entered against you without a hearing and you may lose your property or other important YOU should take this notice to a lawyer at once. If one, go to or telephone the following _you do not have a lawyer or cannot rights. ~, office to fred out where you can get legal help: afford Court Administrator Cumberland County Courthouse Carlise, PA 17013 (717) 240-6200 IHUR LASHIN, ESQ--, HAYT, HAYT & LANDAU BY: ARTHUR LASHIN, ESQUIRE IDENTIFICATION NO. 23425 - SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106-2509 (215) 928-1400 A'I-rORNEY FOR PLAINTIFF FORD MOTOR CREDIT COMPANY VS. ADAM WALKER and FAYE L. WALKER CUMBERLAND COUNTY COURT OE C°MMON PLEAS Civil DIVISION TERM, No. 01-6198 Civil Term ORDER TO MARK JUDGMENT'SATISFIED TO THE PROTHONOTARY: Kindly mark the Judgment Satisfied with regard to the above captioned matter upon payment of your costs only. HAYT, HAYT By: Attorney for Plaintiff CRR?IFICA?R PRRRROUISI~R TO SRRVIC~ 0~ A SUBPOENA PURSUANT TO RUL~ 400~.22 IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILL0 COURT OF COMMON PLEAS TERM, -VS- CASE NO: 2~0C1-6918 JOHN ROSENBERRY AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 02/24/2003 /'"~S on ~,~1~,.~ o~ ANDREW-C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-394996 2 O 8 74 --LO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: JOHN P. ILL0 & JANICE L. ILL0 -VS- JOHN ROSENBERRY COURT OF COMMON PLEAS TERM, CASE N0: 2001-6918 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCR ~S ~ FOR DISCOVerY ~,U~U.~UA.N'I' TO RUI~ 4009.21 SHIPPENBURG HEALTH SERVICES BRANCH CREEK PHYSICIANS CUMBERLAND VALLEY ORTHO. ASSOC ORTHOPAEDIC ASSOCIATES CHAMBERSBURG HOSPITAL STATE FARM INSURANCE COMPANY MEDICAL RECORDS & XRAYS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS INSURANCE TO: MARCUS MCKNIGHT, ESQUIRE #CS on behalf of ANDREW C. LEHMAN, 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 NCS or by contacting our local ~CS office. DATE: 02/04/2003 CC: ANDII. A'W C. LBH1MI~, BSQ. - 01-545 ~CS on behalf of ANDREW C. LEHMAN~ ESQ. Attorney for DEFBNDAI~ Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-214763 2 0 8 7 4 --CO I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN P.ILLO AND JANICE L.ILLO VS JOHN ROSENBERRY File No. ~001-6918 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: SHIPPENSBURG HEALTH SERVICES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address li~ted above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things ~ought. 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: ANDREW C. LEI~a. lq. ESO. ADDRESS: 2411 NORTH FRONT ST. H/iRRTRRI~('.._PA 1 71113 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT 02/24/2003 BY 'I~E COUxRT:' ~'5'~ ~ Pgt~nomy/c~,r~. Civil ~'o~ Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHIPPENBURG HEALTH SERVICES 46 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257 RE: 20874 JOHN P. ILLO Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: JOHN P. ILLO P.O. BOX 115, NEWBURG, PA 17240 Social Security #: 148.-16-6673 Date of Birth: 04-10-1926 SU10-423122 2 0 8 74 --LO 1 C~RTIPICATR PR~R~0UISIT~ TO SRRVIC~ OF A SUBPORNA PURSUANT TO RUL~ 4009.22 IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILL0 COURT OF COMMON PLEAS TERM, JOHN ROSENBERRY -VS- CASE NO: 2001-6918 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 02/24/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-394997 2 O 8 74 --LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILL0 -VS- JOHN ROSENBERRY COURT OF COMMON PLEAS TERM, CASE NO: 2001-6918 NOTICE OF ~ TO S]~VE A SUBPOi~A TO PRODUCE ~S AND · ru~ FOR DISCO~¥ PURSUANT TO R~n'.~ 4009.21 SHIPPENBURG HEALTH SERVICES MEDICAL RECORDS & XRAYS BRANCH CREEK PHYSICIANS MEDICAL RECORDS CUMBERLAND VALLEY ORTHO. ASSOC MEDICAL RECORDS ORTHOPAEDIC ASSOCIATES MEDICAL RECORDS & XRAYS CHAMBERSBURG HOSPITAL MEDICAL RECORDS STATE FARM INSURANCE COMPANY INSURANCE TO: MARCUS MCKNIGHT, BSQUIRE MCS on behalf of ANDREW C. LEHMAN, 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: 02/04/2003 CC: ANDR~IIC. T.mnOdl, ESQ. - 01-545 ~CS on behalf of A~DP.~C. LEmmqe, ES9. Attorney for DRFRNDAI~ Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STRRET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-214763 2 0 8 7 4 --CO 1 --' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN P.ILL0 AND JANICE L.ILLO VS JOHN ROSENBERRY ' File No. 2001-6918 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: BRANCH CREEK PHYSICIANS (Name of Pemon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED . at MCS GROUP INC., 1601 I~,REKT ST., #800, PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the document~ 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: ANDR~ C.LEI~IAN. ESO. ADDRESS: 2411 NORTIt FRONT ST. I-IARRTRRTT~_PA 1 71 1~ TELEPHON~ 2 ~ 5-246-0900 SUPREME CO~T ID ~ A~O~ FO~ DE~~ DATE: 02/24/2003 -- BY2~IE COURT.'-~ ~ Del~ut£ SeaJ of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BRANCH CREEK PHYSICIANS 67 WEST KING STREET SHIPPENSBURG, PA 17257 RE: 20874 JOHN P. ILLO Entire medical f'de, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, ~es, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: JOHN P. ILLO P.O. BOX 115, NEWBURG, PA 17240 Social Security #: 148-16-6673 Date of Birth: 04-10-1926 SU10-423124 2 0 8 74 --LO 2 CRRTI~ICATg PRRRg0UISITR TO SRRVICg OF A SUBPOgNA PURSUANT TO RULR 400~.22 IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILL0 COURT OF COMMON PLEAS TERM, JOHN ROSENBERRY -VS - CASE NO: 2001-6918 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 02/24/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-394998 2 O 8 74 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILL0 -VS- JOHN ROSENBERRY COURT OF COMMON PLEAS TERM, CASE NO: 2001-6918 NOTICE OF ~ TO SERVE A SUBPOENA TO PI~O_nUCE ~S AND 'r~i~S ~R DISCO%flsKY PO~uANT TO RUr.R 4009.21 SEIPPENBURG HEALTH SERVICES MEDICAL RECORDS & XRAYS BRANCH CREEK PHYSICIANS MEDICAL RECORDS CUMBERLAND VALLEY ORTHO. ASSOC MEDICAL RECORDS ORTHOPAEDIC ASSOCIATES MEDICAL RECORDS & XRAYS CHAMBERSBURG HOSPITAL MEDICAL RECORDS STATE FARM INSURANCE COMPANY INSURANCE TO: ~ARCUS ~CKNIGHT, ESQUIRE MCS on behalf of ANDREW C. LEE~%N, 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 ~CS or by contacting our local ~CS office. DATE: 02/04/2003 CC: ANDREW C. LEHMAN, ESQ. - 01-545 MCS on behalf of a~DR~ C. LEHMAN, Attorney for DRFRNDANT Any questions regarding this matter, contact THR NCS GROUP INC. 1601 NARKRT STP. RET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 ' DE02-214763 2 0 8 7 4 -- C 0 I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN P.ILLO AND VS JOHN ROSENBERRY JANICE L. ILLO File No. ~001-6918 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND COUNTY ORTHOPEDIC ASSOC. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the cour~ to produce the following documents or things: SEE ATTACHED , at MCS GROUP INC., 1601 MAREKT ST., t~800, PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the document~ 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: ANDREW C.LEHMAN. ESO. ADDRESS: 2411 NORTH FRONT ST. HARRTRRITR~:PA 1711fi TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATrORNEY FOIl: DEFENDANT DATE: | 02/24/2003 BYTj~COU/RT: "~ r~.~ P~thono~/Clerk, Civil Seal of the Cour~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND VALLEY ORTHO. ASSOC 120 N. 7TH STREET/STE 10 CHAMBERSBURG MED. BL CHAMBERSBURG, PA 17201 RE: 20874 JOHN P. ILLO Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: JOHN P. ILLO P.O. BOX 115, NEWBURG, PA 17240 Social Security #: 148-16-6673 Date of Birth: 04-10-1926 SU10-423126 2 0 8 74 --T.O 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILLO COURT OF COMMON PLEAS TERM, JOHN ROSENBERRY -VS - CASE NO: 2001-6918 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 02/24/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-394999 2 O 8 74 --T.O4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILL0 -VS- JOHN ROSENBERRY COURT OF COMMON PLEAS TERM, CASE NO: 2001-6918 NOTIC~ OF ~ TO SERVE A SUBPO~IA TO PI~_ODUC~ ~S AND '£U~S ~Oi( DISC~¥~Y ['U~t~UANT TO RU~.R 4009.21 SHIPPENBURG HEALTH SERVICES BRANCH CREEK PHYSICIANS CUMBERLAND VALLEY ORTHO. ASSOC ORTHOPAEDIC ASSOCIATES C~%~BERSBURG HOSPITAL STATE FAR~ INSURANCE COMPANY ~DICAL RECORDS & XRAYS ~DICAL R~CORDS ~DICAL RECORDS ~DICAL RECORDS & XRAYS MEDICAL RECORDS INSUR~CR .TO: ~ARCUS MCF~IGHT, ESQUIRE #CS on behalf of ANDR~ C. LEH~,%N, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty 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 ~CS or by contacting our local MCS office. DATR: 02/04/2003 CC: AND~C. LKHMMW, ESQ. - 01-545 MCS on behalf of AND~ C. LE~ ES9. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET J800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-214763 2 O 8 7 4 -- C O i COMMONWEALTH OF PENNSYLVANIA JOHN P.ILLO AND VS JOHN ROSENBERRY COUNTY OF CUMBERLAND JANICE L. ILLO File No. 2001-69~8 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-29 TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC ASSOC. (Name of Per~on or Enti~) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN. ESQ, ADDRESS: 2411 NORTH FRONT ST. ~IARnT RRITRC_ PA TELEPHONE: 215-246-0900 SUPREME COURT ID ATTORNEY FOR: DEFENDANT DATE: 02/24/2003 - - Prothonotary/~ler~ Civil ~j~n Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC ASSOCIATES 1035 WAYNE AVE CHAMBERSBURG, PA 17201 RE: 20874 JOHN P. ILLO INCLUDING ANY AND ALL MRI'S. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray fflm. s and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: JOHN P. ILLO P.O. BOX 115, NEWBURG, PA 17240 Social Security #: 148-16-6673 Date of Birth: 04-10-1926 SU10-423128 2 0 8 74 --T.04 C~RTIFICAT~ PRRRRQUISITg TO SgRVICR OP A SUBPOgNA PURSUANT TO RULE 400~.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN P. ILL0 & JANICE L. ILL0 TERM, -VS- CASE NO: 2001-6918 JOHN ROSENBERRY AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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 w~ich is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 02/24/2003 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-395000 20 8 74 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILL0 -VS- JOHN ROSENBERRY COURT OF COMMON PLEAS TERM, CASE N0: 2001-6918 NOTICE OF INTENT TO SERVE A SUBPOK~A TO PRODU_C~ IX)CUMI/NTS 'l~l~ FOR DISCO%~tY PU~U~UAN~ TO RU~.~ 4009.2! SHIPPENBURG HEALTH SERVICES MEDICAL RECORDS & XRAYS BRANCH CREEK PHYSICIANS MEDICAL RECORDS CUMBERLAND VALLEY ORTHO. ASSOC MEDICAL RECORDS ORTHOPAEDIC ASSOCIATES MEDICAL RECORDS & XRAYS CHAMBERSBORG HOSPITAL MEDICAL RECORDS STATE FARM INSURANCE COMPANY INSURANCE TO: MARCUS MCKNIGHT, ESQUIRE MCS on behalf of ANDREW C. LEHMAN, 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 ~S or by contacting our local NCS office. DATE: 02/04/2003 CC: AND~ C. n~U. AN, ESQ. - 01-545 MCS on behalf of ANDRENC. LEHMAN, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 8600 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-214763 20 8 7 4 -- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN P.ILLO AND VS JOHN ROSENBERRY JANICE L. ILLO File No. 2001-6918 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL (Name of Per~on or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MAREKT ST., /~800, PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce thing~ 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 copie~ 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: ANDREW C. L]~HMAN, ESO. ADDRESS: 2411 NORTH FRONT ST. NAIH~T.~RITI~f'.:'PA 1 71 1 fl TELEPMONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT ] 02/24/2003 DATE: ~A)- ~O( Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL 112 NORTH SEVENTH ST. CHAMBERSBURG, PA 17201 RE: 20874 JOHN P. ILLO Entire ho~ital medical f'rie, including but not limited to any and all records, corresponaence to and from the consulting and/or treating physician, fries, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, tests, and/or medication, lab and diagnostic test results, including ao.y and all such items as may be stored in a computer database or otherwise m electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: JOHN P. ILLO P.O. BOX 115, NEWBURG, PA 17240 Social Security #: 148-16-6673 Date of Birth: 04-10-1926 SU10-423130 2 0 8 74 --LO 5 CERTIFICATE PRBREOUISITE TO SERVICE OF A SUBPOENA PURSO2~ TO RULE 400).22 IN THE MATTER OF: JOHN P. ILL0 & JANICE L. ILLO COURT OF COMMON PLEAS TERM, JOHN ROSENBERRY -VS - CASE NO: 2001-6918 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, 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: 02/24/2003 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-395001 20 8 74 -LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: JOHN P. ILL0 & JANICE L. ILL0 -VS- JOHN ROSENBERRY COURT OF COMMON PLEAS TERM, CASE NO: 2001-6918 NOTICE OF INTENT TO SERVE A SUBPOEN~ TO PRODUCE ~S AN~ · rnJ_NGS FOR DISC~)Vi~KY PO--I~SUANT TO RUT.R 4009.21 SHIPPENBURG HEALTH SERVICES BRANCH CREEK PHYSICIANS CUMBERLAND VALLEY ORTHO. ASSOC ORTHOPAEDIC ASSOCIATES CHANBERSBURG HOSPITAL STATE FARM INSUP. ANCE CONP~2~Y MEDICAL RECORDS & XRAYS NEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS & XRAYS MEDICAL RECORDS INSURANCE TO: MARCUS NCKNIGHT, ESQUIRE MCS on behalf of ANDREW C. LEHMAN, 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 NCS office. DATE: 02/04/2003 CC: ANDREW C. LRHNAN, ESQ. - 01-545 NCS on behalf of ANDREW C. LEHF~%N, ESQ. Attorney for DEFENDANT Any questions regarding 'this matter, contact THE NCS GROUP INC. 1601 MARKET STREET #800 PHII~ELPHIA, PA 19103 (215) 246-0900 DE02-214763 2 O 8 7 4 --CO 1 coMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN P. ILLO AND VS JOHN ROSENBERRY JANICE L. ILLO File No. 2001-6918 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: STATE FARM INSURANCE COMPANY (Name of Per~on or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MAREKT ST., #800, PHILA.PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANDREW C. LEHMAN. ESO. ADDRESS: 2411 NORTH FRONT ST. RARRTRRITRO.:PA 1711(1 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFEND~N~ 02/24/2003 DATE: ,~ J.,F-JA ~) ! Seal of the Court Prot honotary/CleLk, Civil~li~on Deput3~ (~f. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STATE FARM INSURANCE COMPANY P.O. BOX 14007 1690 KENNETH ROAD YORK, PA 14007 RE: 20874 JOHN P. ILLO Any and all insurance records and PIP fries, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested:up to and including the present. Subject: JOHN PL ILLO P.O. BOX 115, NEWBURG, PA 17240 Social Security #: 148-16-6673 Date of Birth: 04-10-1926 Date of Loss: 12/10/1999 SU10-423132 2 0 8 74 --LO 6