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Home My WebLink About07-5129 Besima Becirovic, Plaintiff v. Donald J. Knox, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07- ~~~1 CIVIL -LAW PItAECIPE FOR WRIT OF SUMMON To: Cumberland County Prothonotary: Please issue a Writ of Summons in the above captioned matter against Donald J. Knox, Defendant. Donald J. Knax 2321 Treymore Lace Charlotte, NC 28262 Date: ~~ `~ v( ~ ~~ Mazk F. Bayley, Esquire BAYLEY ~ MANGAN 17 West South St. Cazlisle, PA 17013 ID # 87663 Attorney for Plaintiff J Besima Becirovic, Plaintiff . v. Donald J. Knox, Defendant . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY, PENNSYLVANIA NO.O~ - 5~~ a 9 _ CIVII, -LAW ~rtlu-a Vi yva~aasva. To: Donald J. Knox 2321 Treymore Lane Charlotte,, NC 28262 You are hereby notifed that Besima Becirovic, by and through her attorney, Mark F. Bayley, Esquire, has commenced an action against you in connection with an automobile accident that occurred on or around August 27, 2005. Date: 7 w Seal of the Court ro V \. -c~ v C"3 ~ O C~ o -r9 ~~~?' ~ ~ `f- ~ N -- i 13~ ; . , ~ ~ j ~ <_ ! "'~~ -r. v ~ ~= ~ ~ N ~- ~~ r Johnson, Duffle, Stewart & Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr@jdsw.com Attorneys for Defendant, Donald J. Knox Besima Becirovic, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, DOCKET NO: 07-5129 Donald J. Knox, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly issue a Rule to the Plaintiff to file its Complaint with twenty (20) days of the date of service thereof, or suffer judgment of non pros. ohnson, Duffle, Stew~t & Weidner Je a B. Rettig, Esquire A rn y I.D. No: 19616 3 1 arket Street Lemoyne, Pennsylvania 17043-0109 717.761.4540 Attorney for Additional Defendant Donald J. Knox Date: October 18, 2007 _~ Johnson, Duffle, Stewart & Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr~jdsw.com Attorneys for Defendant, Donald J. Knox Besima Becirovic, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. : DOCKET NO: 07-5129 Donald J. Knox, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED RULE TO FILE COMPLAINT AND NOW, this to day of ~~ohpr , 2007, a Rule is hereby issued to you to file your Complaint in the above-captioned action within twenty (20) days of the date of service hereof, or suffer judgment of non pros. Prothonotary, By: D~ 1:3C}~d~ .1 . Johnson, Duffle, Stewart & Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr~jdsw.com Attorneys for Defendant, Donald J. Knox Besima Becirovic, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO: 07-5129 Donald J. Knox, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have served a copy of the foregoing Praecipe upon all parties of interest in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure by depositing a copy of the same in the United States Mail, first-class postage pre-paid as follows on this 18~' day of October, 2007: Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, Pennsylvania 17013 Johnson, Duffe, Stewart ~ Weidner By: Esquire 313392 r ti ; ; ~t~ Y1. ~ --~i ~+~'~ •- t ~w •,s~ ...` ,- tY.3 `-`~-t .~ ~ MC 4 Johnson, Duffle, Stewart & Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr~jdsw.com Attorneys for Defendant, Donald J. Knox Besima Becirovic, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO: 07-5129 Donald J. Knox, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary of Cumberland County: Kindly enter my appearance on behalf of Defendant, Donald J. Knox, in the above- captioned action. Respectfully submitted, .l~hnson, Duffle, Steyyart ~ Weidner Date: October I8, 2007 By: Je re B. Rettig, Esq A o ey I.D. No. 1961 3 Market Street Lemoyne, Pennsylvania 17043 717.761.4540 jbr~idsw.com Attorney for Defendant, Donald J. Knox • Johnson, Duffle, Stewart & Weidner By: Jeffrey B. Rettig, Esquire LD. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbrr~jdsw.com Attorneys for Defendant, Donald J. Knox Besima Becirovic, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO: 07-5129 Donald J. Knox, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Praecipe for Entry of Appearance has been duly served upon all counsel of record and parties of interest by placing the same in the United States Mail postage pre-paid on this 18~' day of October, 2007, and addressed as follows: Mark F. Bayley, Esquire Bayley ~ Mangan 17 West South Street Carlisle, Pennsylvania 17013 Johnson, Duffle, ~ Weidner 313390 C ' r.~ c~ ~ ; ...~ Z7 ~-, ~:'. c~ :~ -: ; t-, .~ p~ ti ~ ~ ~ _ ~~ 1~ ~ e Besima Becirovic, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, , PENNSYLVANIA v. N0.07 - 5129 Donald J. Knox, Defendant CIVIL -LAW NOTICE TO DEFEND 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 aze served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You aze warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Baz Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. Besima Becirovic, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA v. N0.07 - 5129 Donald J. Knox, Defendant CIVII. -LAW COMPLAINT 1. Plaintiff, Besima Becirovic, is an adult individual residing at 1896 Mary Lane, Carlisle, Pennsylvania. 2. Defendant, Donald J. Knox, is an adult individual residing at 2321 Treymore Lane, Charlotte, North Carolina. 3. On or about August 27, 2005, Plaintiff was operating her vehicle traveling north on Route 11 as she approached the driveway of the Mote16 in Cumberland County, Pennsylvania. 4. At the same time, Defendant was attempting to make a left turn from the Mote16 driveway in order to proceed south on Route 11. 5 Despite Plaintiff having the right-of--way, Defendant pulled out from the driveway and stuck the right front portion of Plaintiffs vehicle. 6. Plaintiffs vehicle subsequently crossed the oncoming lane of traffic and went up over the embankment on the southbound berm striking various objects. 7. The impacts occurred as a direct and proximate result of the Defendant's negligence. 8. The defendant was negligent in, including but not limited to, the following respects: a) failing to maintain a proper lookout; b) failing to drive within the assured clear distance ahead; c) failing to operate his vehicle in a safe and prudent manner; d) failing to stop his vehicle before he collided with Plaintiff; and e) failing to yield the right-of--way pursuant to the Vehicle Code. 9. As a direct and proximate result of the negligence of Defendant, Plaintiff suffered injuries, and / or aggravation of possible pre-existing conditions(s), including but not limited to, her abdomen and supporting structures. 10. As a result of her injuries, Plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts that may not be covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 11. As a result of her injuries, Plaintiff has incurred pain and suffering and may incur the same in the future. 12. As a result of her injuries, Plaintiff has incurred aggravation, inconvenience, disability, and a loss of life's pleasures, and may continue to incur the same in the future. 13. As a result of her injuries Plaintiff lost wages and Plaintiff s economic horizons may be limited. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to azbitration. A jury trial is hereby demanded. Respectfully submitted, Date: ... .,~ Mazk F. Bayley, Es ' e 17 West South Street Cazlisle, PA 17013 (717) 241-2446 Supreme Court ID# 87663 Attorney for Plaintiff Besima Becirovic, Plaintiff v. Donald J. Knox, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07 - 5129 CIVIL -LAW VERIFICATION Besima Becirovic states that she is Plaintiff in this action; that she makes the allegations in the forgoing Complaint with sufficient knowledge or information and belief, based upon her investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: /~ ~O ~ ~C? 7 ~~S^/~vt cf ~~ c ~rc~v~ ~ Besima Becirovic • ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.07 - 5129 CIVIL -LAW CERTII~'ICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiff do hereby certify that I this day served a Besima Becirovic, Plaintiff v. Donald J. Knox, Defendant copy of the within Complaint upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Jeffrey B. Rettig, Esquire 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 ~ ~~ Dated: -- Mark F. Bayley, Esq ' e Attorney for Plaintiff ~J ~ ~ C~ C. c- ~ -r1 ~~ . ~ ~ r t ~ -` r-- N .. ~ "' r ~ - = _ --~-T .- '.. -- - `-._ . r . - . .~ ~, C.~i ,.- =~ Johnson, Duffie, Stewart & Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr@jdsw.com Besima Becirovic, v. Plaintiff Donald J. Knox, Defendant To: Besima Becirovic, Plaintiff c/o Mark F. Bayley, Esquire Bayley 8~ Mangan 17 West South Street Carlisle, Pennsylvania 17013 Attorneys for Defendant, Donald J. Knox IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 07-5129 CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE TO PLEAD You are hereby notified to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, Joh +~.d~?e, ~ev}art ~ Weidner .~ef~'ey B. Rettig, Esquire J A orney I.D. No: 19 6 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbrt7a jdsw.com Dated: November 14, 2007 Attorney for Defendant, Donald J. Knox Johnson, Duffle, Stewart 8 Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr@jdsw.com Attorneys for Defendant, Donald J. Knox Besima Becirovic, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. DOCKET NO: 07-5129 Donald J. Knox, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT DONALD J. KNOX TO PLAINTIFF'S COMPLAINT AND NOW comes Defendant, Donald J. Knox (hereinafter "Defendant") by and through his attorneys, Johnson, Duffle, Stewart 8~ Weidner, and answer Plaintiffs Complaint as follows: 1. It is admitted that the Plaintiff is who she says she is. As to the balance of the allegations of this paragraph, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of said allegations and strict proof thereof is demanded. 2. Admitted. 3. Admitted. 4. Denied. To the contrary, Defendant was stopped in anticipation of making a left hand turn from the Motel 6 driveway in order to proceed onto Route 11 when his vehicle was struck by Plaintiffs vehicle. 5. Denied as stated. The allegation regarding Plaintiff having the right of way is denied as a conclusion of law. It is specifically denied that the Defendant pulled out from the driveway and struck Plaintiffs vehicle. To the contrary, Defendant's vehicle was stopped at the time it was struck by Plaintiffs vehicle. 6. Denied as stated. It is admitted that Plaintiffs vehicle proceeded along Route 11 and off of Route 11 after striking Defendant's vehicle. 7. Denied. To the contrary, the initial impact between the Plaintiffs vehicle and the Defendant's vehicle was as a result of the Plaintiffs negligence. 8. Denied pursuant to Pa. R.C.P. 1029. 9. Denied. The allegations of negligence are denied pursuant to Pa. R.C.P. 1029. As to the balance of the allegations of this paragraph, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of said allegations and strict proof thereof is demanded. 10-13. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of said allegations and strict proof thereof is demanded. WHEREFORE, Defendants request that Plaintiffs Complaint be dismissed without cost to him. NEW MATTER 14. If Plaintiff is subject to the limited tort option, then Plaintiffs claims for non-economic damages are barred. 15. Plaintiff has or may have failed to mitigate her damages. 16. Plaintiffs' claims are or may be barred by the applicable statute of limitations. WHEREFORE, Defendant requests that Plaintiffs Complaint be dismissed without cost to him. submitted, rt 8llWeidner iJRe ,Esquire .D. 19616 Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 ibr _jdsw.com Dated: November 14, 2007 Attorney for Defendant, Donald J. Knox Johnson, Duffie, Stewart & Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr@jdsw.com Besima Becirovic, Plaintiff v. Donald J. Knox, Defendant RECEIVED NOV t ~ 2007 JOHNSON, DUFFiE STEWART AND WEIDNER Attorneys for Defendant, Donald J. Knox IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 07-5129 CIVIL ACTION -LAW JURY TRIAL DEMANDED VERIFICATION I am the Defendant in the above-captioned action, and I hereby verify and state that the facts set forth in the foregoing Answer and New Matter of Defendant to Plaintiff s Complaint are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn verification to authorities. Dated: / 11 b 315464 Johnson, Duffie, Stewart 8 Weidner By: Jeffrey B. Rettig, Esquire I.D. No. 19616 301 Market Street Post Office Box 109 Lemoyne, Pennsylvania 17043-0109 717.761.4540 jbr~jdsw.com Besima Becirovic, Plaintiff v. Donald J. Knox, Defendant Attorneys for Defendant, Donald J. Knox IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 07-5129 CIVIL ACTION -LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Answer and New Matter of Defendants to Plaintiffs' Complaint has been duly served upon all counsel of record and parties of interest by placing the same in the United States Mail postage pre-paid on this 14~' day of November, 2007, and addressed as follows: Mark F. Bayley, Esquire Bayley 8~ Mangan 17 West South Street Carlisle, Pennsylvania 17013 J n, Duffie, St art ~ Weidner By: Je r y B. Rettig 315455 r-> p -n ~ G3 i"T ; ~ +Ga ~""'~ ~~ ~ ~ Y. -si ' - C~r . ' _„. ,~.,~, ....~ ~ t .~ ~' Besima Becirovic, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA v. N0.07 - 5129 Donald J. Knox, Defendant CIVII. -LAW PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER 14. Paragraph 14 states legal conclusion to which no response is required. To the extent, however, a response is deemed necessary, said averments are denied. 15. Paragraph 15 states legal conclusion to which no response is required. To the extent, however, a response is deemed necessary, said averments are denied. 16. Paragraph 16 states legal conclusion to which no response is required. To the extent, however, a response is deemed necessary, said averments are denied. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment in her favor and against the Defendant. oa.. ~ l,Z~_a~ Respectfully submitted, Mark F. Bayley, Es ire 17 West South S et Carlisle, PA 17013 (717) 241-2446 Supreme Court ID# 87663 Attorney for Plaintiff • - Besima Becirovic, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA v. . . N0.07 - 5129 Donald J. Knox, Defendant CIVII. -LAW VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ~ _,_, f ~ v Mark F. Bayley, Es ire Attorney for Plaintiff ! ~ Besima Becirovic, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA v. . N0.07 - 5129 Donald J. Knox, Defendant CIVIL -LAW CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiff do hereby certify that I this day served a copy of the forgoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Jeffrey B. Rettig, Esquire 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 ~ ~ Dated: F. Bayley, Esquir Attorney for Plaintiff C"s ~ .~ t: ~" 1~.3 -'~~ ~ i , ~~~ _ .. ::.~ `~~ . ,. _~ _, _ _:, , ~_ r ~.rt_ r t'~,~ , .. ~ k"i"~ --t ; C -.J "+.a °„~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA ~ ~P~,I~C i~ PURSUANT TO RULE 4009.22 IN THE MATTER OF: BESIMA BSEIROVIC -VS- DONALD KNOX COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5129 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFREY B. RETTIG, ES certifies that (1} A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. j~ CS b al of // ~ ~ ` DATE: 12/20/2007 FR B. ETTIG ESQ. ney for DEF DANT R1.50 133-H DE11-0726933 62883-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BESIMA BSEIROVIC -VS- DONALD KNOX COURT OF COMMON PLEAS TERM, CASE NO: 07-5129 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MET LIFE AUTO & HOME INSURANCE DR. ALEXANDER SPASIC MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS TO: MARK F. BAYLEY, ESQ., PLAINTIFF COUNSEL MCS on behalf of JEFFREY B. RETTIG, 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: 11/30/2007 CC: JEFFREY B. RETTIG, ESQ. - 014775.98 Any questions regarding this matter, contact MCS on behalf of JEFFREY B. RETTIG, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0380835 62883 -COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BESIMA BSEIROVIC vs. File No. 07-5129 DONALD KNOX SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MET 1F . Ai IT(~ ~ un~t~ (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: **** ATTA n RT1~FR **** at The MC row Inc t 601 M rket tr t Si ite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If.you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: _JEFFREY B RETTIG ESO ADDRESS: 301 M RKF.T STREET ~.0. BOX 109 ~EMOYNF. PA 1704 TELEPHONE: (2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DEC 2 0 2001 Date: _~ 02~ oC~d'7 Seal of the Court BY THE COURT: 1-S/ ~~~u ~ ~' Prothonotary/Clerk, Civil Divi a~+.~- ~. Deputy 62883-01 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: MET LIFE AUTO & HOME P.O. BOX 1509 LATHAM, NY 12110 RE: 62883 BESIMA BESIROVIC Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all insurance records and PIP files, 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 as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 08-27-2005 to 11-01-2007. Subject BESIMA BESIROVIC CARLISLE, PA 17013 Social Security #: XXX-XX-5341 Date of Birth: 10-05-1976 Date of Loss: 08/27/2005 R1.49S 133-H SU10-0713704 62883 -LOl IN THE MATTER OF: BESIMA BSEIROVIC DONALD KNOX CERTIFICATE ~ ~ ~:. ~ 1r/JVA~ PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 07-5129 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFREY B. RETTIG, 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: 12/20/2007 ~~~ CS beh~ f o R B. RE IG, E / o ney for DEFEND R1.50 133-H DEll-0726934 62883-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BESIMA BSEIROVIC -VS- DONALD KNOX COURT OF COMMON PLEAS TERM, CASE NO: 07-5129 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MET LIFE AUTO & HOME INSURANCE DR. ALEXANDER SPASIC MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS TO: MARK F. BAYLEY, ESQ., PLAINTIFF COUNSEL MCS on behalf of JEFFREY B. RETTIG, 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: 11/30/2007 CC: JEFFREY B. RETTIG, ESQ. - 014775.98 Any questions regarding this matter, contact R1.49S 133-H MCS on behalf of JEFFREY B. RETTIG, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0380835 62883-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BESIMA BSEIROVIC vs. File No. _ 07-5129 DONALD KNOX SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR AT .FX NT)FR PA I (Name of Person or Entity) Within twenty (20) days after service of this subpoena,. you aze ordered by the court to produce the following documents or things: **** SEE ATTA H D TT1FR **** at __ The MCS C'ro~,, I~ 1601 M rke Ctr et St~;rP 800, P ilad (hhia" PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JEFFREY B. RETTIG ESO ADDRESS: 301 M KFT F .T ~.0. BOX 109 LEMOYNE, PA 17043 TELEPHONE: (2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: ,~ OE 2 0~~ ~~0 7 Date: Seal of the Court Prothonotary/Clerk, Civil Divisio€f Deputy ~~ 62883-02 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: DR. ALEXANDER SPASIC 816 BELVEDERE STREET CARLISLE, PA 17013 RE: 62883 BESIMA BESIROVIC Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: from: O1-O1-2002 to 11-01-2007. Subject BESIMA BESIROVIC CARLISLE, PA 17013 Social Security #: XXX-XX-5341 Date of Birth: 10-05-1976 R1.49S 133-H SU10-0713706 62883-LO2 IN THE MATTER OF: BESIMA BSEIROVIC DONALD KNOX CERTIFICATE ;~ ~/~ AO !I ~~ PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 07-5129 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFREY B. RETTIG, 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: 12/20/2007 S beha~ of /J r RE B. RETTIG, ES I o ey for DEFENDAI T R1.50 133-H DE11-0726935 62883 -L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: BESIMA BSEIROVIC -VS- DONALD KNOX COURT OF COMMON PLEAS TERM, CASE NO: 07-5129 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MET LIFE AUTO & HOME INSURANCE DR. ALEXANDER SPASIC MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS TO: MARK F. BAYLEY, ESQ., PLAINTIFF COUNSEL MCS on behalf of JEFFREY B. RETTIG, 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: 11/30/2007 CC: JEFFREY B. RETTIG, ESQ. - 014775.98 Any questions regarding this matter, contact MCS on behalf of JEFFREY B. RETTIG, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DR02-0380835 62883 -COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BESIMA BSEIIZOVIC . File No. 07-5129 vs. DONALD KNOX SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for C RT i4i F F ION T b~ DI T CT`1'-'R (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the followin documents or things: **** ATTA n ~n'ER **** g at _ Th M Groun. Inc.. 1601 M rket tr ..t, SnitP 800 Philad lphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JEFFREY B FTTIG ES ADDRESS: 301 MARKET cTRRRT TELEPHONE: (2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DEC 2 0 2007 Date: ~Gr~~y,,,~rL( AFT SOU ~ Seal of the Court BY THE COURT: ,~~ ~~ ,~ ~ Prothonotary/Clerk, Civil Divisi Deputy 62883-03 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS 361 ALEXANDER SPRING CARLISLE. PA 17Q15 RE: 62883 BESIMA BESIROVIC Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: from: 01-01-2002 to 11-O1-2007. Subject BESIMA BESIROVIC CARLISLE, PA 17013 Social Security #: XXX-XX-5341 Date of Birth: 10-05-1976 R1.49S 133-H solo-o7137oa 62883-L03 C) ~~' ~ C~ ~ "`~ Pte. ~ ~l ~ ~ r~C G . ~?-~} " " r~ ~ ;s L .C - --r; ~ ~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BESIROVIC Vs. . . NO. 075129 KNOX . 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 JEFFREY B RETTIG, 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: 05/02/08 ~z File #: M351241 JEFFREY B RETTIG, ESQUIRE 301 MARKET ST PO BOX 109 LEMOYNE, PA 17043 717-761-4540 ATTORNEY FOR DEFENDANT INQIIIRI}35 SHOIILD BE ADDRSS58D TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3581 By: Dorota Wrzos IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BESIROVIC . Vs. KNOX I No. 075129 TO: MARK BAYLEY, 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: 04/11/08 JEFFREY B RETTIG, ESQUIRE 301 MARKET ST PO BOX 109 LEMOYNE, PA 17043 ATTORNEY FOR DEFENDANT INQIIIRIES SHOIILD B8 ADDRESSgD TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 By: Dorota Wrzos Enc (s) : Copy of subpoena (s ) Counsel return card File #: M351241 • ~ COI~I~DNf~ALTH OF PIIdVSYLVANIA QOU[~Tl'Y OF QADID BESIROVIC Vs . File No. KNOX 075129 SUBPOENA TO PRODUCE DOCIJhENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PATTON PICTURE, 207 LYNNDALE CT, MECHANICSBURG PA 17050 TO: ATTN: 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 or thin s: SEE ~T -- at MEDICAL L]3QAL R$PRODIICTIONS,(A~ss4~940 DISSTON ST. , PHILA. , PA You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together wit?i the certificate of canpliance, to the party making thi: request at the ad~^ess 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 1,20) days after its service, the party carpe 11 i ng you to cane 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 THE REQUEST OF THE FOLLOWING PERSON: NAhE:- JEFFREY B RETTIG, ESQ ADDRESS: LEMO 043 TELEPHONE: SUPREhE OOURT I D# 215 - 3 3 5- 3 212 ATTORNEY FOR : _ 19 6 6 DEFENDANT M351241-01 DATE : y ~tcrc: 1 of the Carat BY THE OOURT: Prothonotary/Cler Civil Divisions'-~' / , Deputy (Eff. 7/97) a ADDENDUM TO S UBPOENA BESIROVIC Vs. No. 075129 KNOX CUSTODIAN OF RECORDS FOR : PATTON PICTURE **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: BESIMA BESIROVIC ADDRESS: 1926B FRY LOOP AVE CARLISLE PA DATE OF BIRTH: 10/05/76 SSAN: XXXXX5341 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 PATTON PICTURE M351241-O1 *** SIGN AND RETURN THIS PAGE *** r ADDENDUM Patton Picture Copy of complete personnel/employment file to include, but not limited to, employment application, pre-employment physical, attendence records, wage records, employee evaluation records and any other documents whatsoever contained in the employment file Of B. BeCirovic FROM 1/1/03. ~ ~--~` ~i `» ~€s, ~: ~ ,, . ~~ ~ ~, ~~Y r~