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07-5665
STACIE R. MACKERETH and KELLY W. MACKERETH HUSBAND and WIFE, Plaintiffs V. LAURA K. HAMILTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- 5 CIVIL TERM 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 may be entered against you by the Court without further notice for any money claimed in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 STACIE R. MACKERETH and KELLY W. MACKERETH HUSBAND and WIFE, Plaintiffs vi. LAURA K. HAMILTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- -6 (PS CIVIL TERM COMPLAINT 1. Plaintiffs, Stacie R. Mackereth and Kelly W. Mackereth, adult individuals, are husband and wife residing at 801 Pine Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, Laura K. Hamilton, last known address at 970 Circle Drive, Harrisonburg, Virginia, 22601. 3. On or about October 2, 2005, the Plaintiff, Stacie R. Mackereth, was the operator and owner of a 1994 Pontiac Trans Sport SE. 4. On or about October 2, 2005, the Plaintiff, Stacie R. Mackereth, was driving the same motor vehicle north on Walnut Street at or near Walnut Street's intersection with SR174 in South Middletown Township, Cumberland County, and State of Pennsylvania, the site of a four-way stop after making a full and lawful stop; looking both ways, and at all time maintaining full control of her motor vehicle, entered the intersection and was struck by the motor vehicle driven by Defendant Laura K. Hamilton 5. At that same time and place, the Defendant, Laura K. Hamilton, was the owner and operator of at 1994 Toyota Camry. 6. At that same time and place, Defendant, Laura K. Hamilton, was driving this same motor vehicle east on SR174 at or near the Walnut Street intersection with SR174 in South Middleton Township, Cumberland County and State of Pennsylvania, the site of a four-way stop. 7. Defendant, Laura K. Hamilton, had the duty of observing the four-way stop sign and making a full stop at the intersection of SR174 and Walnut Street before proceeding into the intersection and to do so with due care and caution, in accordance with the applicable statues and ordinances in effect at the said time and place. 8. At the aforementioned intersection, Defendant, Laura K. Hamilton, did negligently, carelessly and recklessly failed to stop at the properly posted four-way stop at the intersection of SR174 and Walnut Street and proceeded into the intersection striking the motor vehicle driven by Plaintiff, Stacie R. Mackereth, in a violent manner in the area of the left rear tire with Defendant's vehicle's front bumper and hood. 9. The immediate result of Defendant's failure to observe the properly posted four-way stop intersection was a violent collision with Plaintiff's motor vehicle. COUNTI STACIE R. MACKERETH V LAURA K. HAMILTON 10. Paragraphs 1 through 9 are incorporated as if fully stated herein. 11. As a direct and proximate result of the aforesaid violent collision, Plaintiff, Stacie R. Mackereth, suffered injuries as a personal and pecuniary nature, including but not limited to lost wages, medical expenses, damage to property, pain and suffering, and physical and emotional trauma, all of which are permanent. 12. The Defendant by her actions, or through her inactions, has failed to fulfill her duty to observe the applicable statutes and ordinances in effect on October 2, 2005 in South Middleton Township, Cumberland County, State of Pennsylvania. 13. Defendant, by her actions, or through her inactions, caused a violent collision with the motor vehicle driven by the Plaintiff. 14. Defendant, by her actions, or through her inactions, has caused damage to the Plaintiff's in excess of $50,000.00. WHEREFORE, the Plaintiffs, Stacies R. Mackereth and Kelly W. Mackereth demand judgment against Defendant, Laura K. Hamilton, for actual damages in an amount of more than $50,000.00. l COUNT II KELLY W. MACKERETH V LAURA K. HAMILTON 15. Paragraphs 1 through 14 are incorporated as fully stated herein. 16. That prior to and at all times herein mentioned, the Plaintiffs, Stacie R. Mackereth and Kelly W. Mackereth, are husband and wife residing at 801 Pine Road, Carlisle, Cumberland County and in the State of Pennsylvania. 17. That as a result of the physical and emotional injuries suffered by the Plaintiff, Stacie R. Mackereth, which are of continuing nature, Plaintiff, Kelly W. Mackereth, her husband has suffered a loss of consortium with his wife, Stacie R. Mackereth. WHEREFORE, The Plaintiffs, Stacie R. Mackereth and Kelly W. Mackereth demand judgment against Defendant, Laura K. Hamilton, for actual damages in an amount of more than $50,000.00. Respectfully Submitted TURO LAW OFFICES L'14-L-'-7'z Date Mic ael R. Smith, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs f VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. A 0 ofaov /?- wdd)6a?k. Date Stac ie R. Mackereth f VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. y Date Kelly W. ackereth STACIE R. MACKERETH and KELLY W. MACKERETH HUSBAND and WIFE, Plaintiffs V. LAURA K. HAMILTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- CIVIL TERM CERTIFICATE OF SERVICE I, Michael R. Smith, Esquire hereby certify that I served a true and correct copy of the attached Complaint, by depositing same in the United States Mail, certified first class, return receipt requested, postage pre-paid on the 26th day of September, 2007, from Carlisle, Pennsylvania, addressed as follows: Laura K. Hamilton 970 Circle Drive Harrisonburg, VA 22601 TURO LAW OFFICES Michael R. Smith, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Supreme Court I.D. No. 87023 77 - r7 ` . 'qml. V. STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 760-7501 FAX: (717) 975-8124 E-mail: sbanko(Mmargolisedelstein.com Attorney for Defendant STACIE R. MACKERETH and KELLY W. MACKERETH, husband and wife, LAURA K. HAMILTON, Plaintiffs Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5665 JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Kindly enter my appearance on behalf of Defendant, Laura K. Hamilton, in the above-captioned matter. Date: 10) , <-/01 MAR OLIS EDELSTEIN By: ?TtFMENIL. BANKO, JR. Attorney for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the 1l?? day of 7Ub , 2007, and addressed as follows: Michael R. Smith, Esquire Turo Law Office 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiffs r U Angela A. Gayman, Sec tary C:? r?'t ? ?i ?? ?"? -,-, t .. .- "`? - ' 1 7 - r, / .. '? ?, _? • y `"? r. STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 E-mail: sbankog-margolisedelstein.com Attorney for Defendant Laura K. Hamilton STACIE R. MACKERETH and KELLY W. MACKERETH, husband and wife, NO. 07-5665 V. LAURA K. HAMILTON, Plaintiffs Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Michael R. Smith, Esquire Turo Law Office 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiffs You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. MARGOLIS EDELSTEIN Dater By: AA STE N L. ANKO, JR Attorn for Defendant, Laura K. Hamilton STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 E-mail: sbanko(a-margolisedelstein.com Attorney for Defendant Laura K. Hamilton STACIE R. MACKERETH and KELLY W. MACKERETH, husband and wife, Plaintiffs V. LAURA K. HAMILTON, Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5665 JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, LAURA K. HAMILTON, TO PLAINTIFFS' COMPLAINT 1. Admitted in part and denied in part. As to the marital status of Plaintiffs and their current residence address, after reasonable investigation, Defendant, Laura K. Hamilton ("Defendant"), is without knowledge of information sufficient to form a belief as to the truth of said averments and, therefore, they are denied. 2. Admitted. 3. Admitted. 4. Admitted in part and denied in part. Defendant is unable to admit or deny the legal conclusions and other characterizations contained in this paragraph as to the conduct of Plaintiff. However, it is admitted that the intersection where the motor vehicle accident occurred was controlled by a four way stop sign and that Defendant entered into the intersection without stopping therefore. 1 5. Admitted. 6. Admitted. 7. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. By way of further answer, to the extent that a response is deemed necessary, the answer contained in paragraph 4 hereof is incorporated herein by reference as if set forth in its entirety. 8. Denied. The answer contained in paragraph 7 hereof is incorporated herein by reference as if set forth in its entirety. 9. Admitted in part and denied in part. Defendant is unable to admit or deny the characterization that the contact between the vehicles was "violent." By way of further answer, the answer contained in paragraph 4 hereof is incorporated herein by reference as if set forth in its entirety. COUNTI STACIE R. MACKERETH V. LAURA K. HAMILTON 10. The answers contained in paragraphs 1 through 9 hereof are incorporated herein by reference as if the same were set forth in their entirety. 11. Denied. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. By way of further answer, with regard to any allegation that Plaintiff sustained personal injury or damages as a result of any conduct on the part of Defendant, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of said averments and, therefore, they are denied. 2 12. Denied as stated. The answers contained in the foregoing paragraphs of this Answer are incorporated herein by reference as if set forth in their entirety. 13. Denied. The answer contained in paragraph 12 hereof is incorporated herein by reference as if set forth in its entirety. 14. Denied. The answer contained in paragraph 11 hereof is incorporated herein by reference as if set forth in its entirety. WHEREFORE, Defendant, Laura K. Hamilton, demands judgment in her favor and against Plaintiff. COUNT II. KELLY W. MACKERETH V. LAURA K. HAMILTON 15. The answers contained in paragraphs 1 through 14 hereof are incorporated herein by reference as if the same were set forth in their entirety. 16. Denied. The answer contained in paragraph 1 hereof is incorporated herein by reference as if the same were set forth in its entirety. 17. Denied. The answer contained in paragraph 11 hereof is incorporated herein by reference as if the same were set forth in its entirety. WHEREFORE, Defendant, Laura K. Hamilton, demands judgment in her favor and against Plaintiff. NEW MATTER 18. The answers contained in paragraphs 1 through 17 hereof are incorporated herein by reference as if set forth in their entirety. 3 19. Plaintiffs' claims for non-economic damages may be limited by their tort selection. 20. Plaintiffs' claims, if any, may be barred by the applicable statute of limitations. WHEREFORE, Defendant, Laura K. Hamilton, demands judgment in her favor and against Plaintiff. MARGOLIS EDELSTEIN F Date: ( 6 By: TEPHEN L. BANKO, JR Atto ney for Defendant, Laura K. Hamilton 4 VERIFICATION I, Laura K. Hamilton, have read the foregoing Answer to Plaintiffs' Complaint. The factual statements contained therein are known by me and are true and correct to the best of my knowledge, information and belief. This statement and verification is made subject to the penalties of 18 Pa. C. S.A. Section 4904, relating to unsworn falsifications to authorities, which provides that, if I knowingly make false averments, I may be subject to criminal penalties. Date: J 0'--`O? , Laura K. Hamilton CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the nited States mail at Camp Hill, Pennsylvania, first- ;V class postage prepaid, on the V I day of , 2007, and addressed as follows: Michael R. Smith, Esquire Turo Law Office 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiffs ?rn Ange M. Gayman, cretary 5 . '".' v t w ? ... r _i3 _._. .__> ` ? r ?? ' ? ?::.. G:J ?.i ,`>>- N. _ i?C? r, ti ?? e- STACIE R. MACKERETH and KELLY W. MACKERETH HUSBAND and WIFE, Plaintiffs V. LAURA K. HAMILTON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- 5665 CIVIL TERM : JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER AND NOW, this 22nd day of February, 2008, comes the within Plaintiffs, by and through their undersigned counsel, John M. Shugars, Esquire, who answer and reply to the new matter of the Defendant as follows, to wit: 18. No responsive pleading is required. 19. The averments of Paragraph 19 constitute a legal conclusion to which no responsive pleading is required. By way of further answer, plaintiffs specifically deny that their claims for non-economic damages may be limited by their tort selection. Instead, plaintiffs' applicable insurance policy evidencing their specific election of the full-tort option will be produced in response to Defendant's Request for Production of Documents Directed to Plaintiffs. 20. The averments of Paragraph 20 constitute a legal conclusion to which no responsive pleading is required. By way of further answer, Plaintiffs specifically deny their claims are time-barred and, in fact, were timely pursued within the applicable statute of limitations. WHEREFORE, the Plaintiffs, Stacie R. Mackereth and Kelly W. Mackereth demand judgment in their favor and against Defendant. Date Respectfully Submitted, TURO LAW OFFICES J66 M. Shugars, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs VERIFICATION I verify that the statements of fact made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 2,- Date . U4,, W Kelly W. ckereth VERIFICATION I verify that the statements of fact made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. o2-aa-o8 Date Stacie R. Mackereth CERTIFICATE OF SERVICE I, John M. Shugars, Esquire, hereby certify that I served a true and correct copy of the within document by FAX and by First Class U.S. Mail, postage prepaid, upon the Attorney for the Defendant, this 22nd day of February, 2008, at Carlisle, Pennsylvania, addressed as follows: Stephen L. Banko, Jr., Esquire Margolis Edelstein Harrisburg Office 3510 Trindle Road Camp Hill, PA 17011 FAX (717) 975-8124 TURO LAW OFFICES /?John 4M. Shugars, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 FAX (717) 245-2165 Supreme Court I.D. No. 44180 Attorney for Defendant ?k TV t- 22 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760039 77834-LO1 COMMONWEALTH OF P 'SY'T,VATIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOMA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ] TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H D802-0395914 77834-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHRISTOPHER J BERO, M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTAC D RIDER**** at The M .roan, Inc 1601 Market Street. Suite 800 PhiladeigbiA: 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: STEPHEN L. BANKO. JR.. ESO. ADDRESS: 3510 TRiNDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE OURT: X. ?Zovz Pro onotary/ Civil vision Deputy Date: jai- Seal of the Court 77834-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHRISTOPHER J. BERG. M.D. 220 WILSON STREET MEDICAL ARTS BLDG. CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING PATHOLOGY RECORDS Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and reports, medication/prescription records, including any and all.such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, care.or treatment pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. XACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738544 77834-LO1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760040 77834-LO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUXZNTS AND THINGS FOR DISCOVERY PURSUANT TO R=Z 4009.21 ( Note: see enclosed list of locations ] TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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 sewed. 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: 06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ_._ Attorney for DEFENDANT THE MCS CROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H DE02-0395914 77834-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. J. CRAIG JURGENSEN, M.D. CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. CARLISLE REGIONAL MEDICAL CTR. HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER CARLISLE REGIONAL HOSPITAL MIRA ORTHOPEDICS EMBARQ DEPARTMENT OF WELFARE SSA-DISABILITY R1.60S 116-H MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS EMPLOYMENT WELFARE RECORDS DISABILITY FILE D902-0395914 77834-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W VS. LAURA K. HAMILTON File No. 07-5665 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for J. CRAIG JUR ENSEN M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RMER **** at The M - un, Inc- 1601 Market Street_ Suite 800. P1LadeVhii , 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: STEPHEN L. BANKO. JR.. ESO. ADDRESS: 3510 TRINDLE ROAD _CAME HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: JU.._ D66A -T-u Seal of the Court BY THE URT: Pro onotary/C evil sion Deputy 77834-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: J. CRAIG JURGENSEN, M.D. 850 WALNUT BOTTOM ROAD BELVEDERE MED'L CTR. CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and x-ray file, including but not.limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and reports, medication/prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: SXS-8%-7489 Date of Birth: 08-10-1969 R1.60S 116-x SU10-0738546 77834-LO2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760041 77834 -L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ] TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ.' Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H DE02-0395914 77834-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. J. CRAIG JURGENSEN, M.D. CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. CARLISLE REGIONAL MEDICAL CTR. HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER CARLISLE REGIONAL HOSPITAL MIRA ORTHOPEDICS EMBARQ DEPARTMENT OF WELFARE SSA-DISABILITY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS EMPLOYMENT WELFARE RECORDS DISABILITY FILE R1.60S 116-H DE02-0395914 77834-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the. court to produce the following documents or things:- ****SEE ATTACHED RIDER**** at The MC un_ Inc., 1601 Market Street, Suite 800, P it A 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: STEPHEN L. BANKO. JR.. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (am) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: _ Defendant BY THIWOURT: 11, Pro notary/Cl i vision Ju-L-Nr-- (' .2mS Deputy Date: Seal of the Court 77834-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS 361 ALEXANDER SPRING CARLISLE, PA 17015 RE: 77834 STACIE R. MACKERETH 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: up to and including the present. Subject : STACIE R. NACKERETB 801 PINE ROAD, CARLISLE, PA 17013 Social Security #:. XXX-XX-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738548 77834-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -vs- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2005 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760042 77834-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPO33NNA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ] TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H DE02-0395914 77834-C01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERO, M.D. J. CRAIG JURGENSEN, M.D. CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. CARLISLE REGIONAL MEDICAL CTR. HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER CARLISLE REGIONAL HOSPITAL MIRA ORTHOPEDICS EMBAR.Q DEPARTMENT OF WELFARE SSA-DISABILITY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS EMPLOYMENT WELFARE RECORDS DISABILITY FILE R1.60S 116-H D902-0395914 77834-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for C Ri.IS F ION T DI AL CTR (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 ATTAC D MM **** at _ The MC =_ Inc.- 1601 Market Street, Suite 800, P it A 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: STEPHEN L BANK-0. JR.. ESQ. ADDRESS: 3510 TRINDLF ROAD CAMP HILL, PA 17011 TELEPHONE: _f215l 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE OUR Prot notary/Cl iv11 Sion Date: Deputy Seal of the Court 77834-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR. 361 ALEXANDER SPRING RD RADIOLOGY DEPT CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. MACKERETH .801 PINE ROAD, CARLISLE, PA 17013 Social Security #: EB8-XX-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738550 77834-LO4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760043 77834-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON ( Note: see enclosed list of locations ) COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ._ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H D302-0395914 77834-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. J. CRAIG JURGENSEN, M.D. CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. CARLISLE REGIONAL MEDICAL CTR. HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER CARLISLE REGIONAL HOSPITAL MIRA ORTHOPEDICS EMBARQ DEPARTMENT OF WELFARE SSA-DISABILITY R1.60S 116-H MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS X-RAY ONLY PATHOLOGY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS EMPLOYMENT WELFARE RECORDS DISABILITY FILE DE02-0395914 77834-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400912 TO: Custodian of Records for CARLISLE REGIONAT. DIC T. CTR (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 RMER **** at The M . _ Inc- 1601 Market Street Suite 800 P iladelnhia 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: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRiNDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY TOUR Prot notary5 ivil sion Date: JL,LL-Ir- Deputy _ ?Ca31?3 Seal of the Court 77834-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR. 361 ALEXANDER SPRING RD PATHOLOGY DEPT CARLISLE. PA 17013 RE : 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all pathology reports and records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.60s 116-H SU10-0738552 77834-LO5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS STACIE R. MACKERETH AND KELLY W. TERM, MACKERETH, H/W CUMBERLAND -vs- CASE NO: 07-5665 LAURA K. HAMILTON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760044 77834-LO6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS STACIE R. MACKERETH AND KELLY W. TERM, MACKERETH, H/W -VS- CASE NO: 07-5665 LAURA K. HAMILTON [ Note: see enclosed list of locations l TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 0611212008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney.for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H D902-0395914 77834-COl >>> LOCATION LIST «< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY CARLISLE REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE R1.60S 116-H DE02-0395914 77834-COI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. VS. File No. 07-5665 LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDIC T, C R (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 ATTA HED MER **** at The MCS Qj=. Inc.. 1601 Market C==L Suite 800, P ilad .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 malting 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: STEPHEN L. BANKO. JR.. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: -(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: bnoA Seal of the Court BY O T: Pro notary/Cler 'sion Deputy 77834-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER MEDICAL RECORDS 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 77834 STACIE R. MACKERETH 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, nurses notes, doctors 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: up to and including the present. Subject : STACIE R. MACKERETS 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: 161-66-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738554 77834-LO6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS STACIE R. MACKERETH AND KELLY W. TERM, MACKERETH, H/W CUMBERLAND -VS- CASE NO: 07-5665 LAURA K. HAMILTON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760045 77834-LO7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed.list of locations ) TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ._ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H D802-0395914 77834-COT >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERO, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY CARLISLE REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE R1.60S 116-H DE02-0399914 77834-COl COMMONWEALTH OF PENNSYLVANIA COUNT` OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. VS. File No. 07-5665 LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: _ **** SEE ATTAC D RMER **** at The MCS (_a=- Inc., 1601 Market Chreet. Suite 800- Philadelnlua. 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: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: 1215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE URT: Pro notary/Cler I 'sion Date: 11 F L ;Zgwls Deputy Seal of the Court 77834-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER RADIOLOGY DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 19182 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. MACKERETB 801 PINE ROAD, CARLISLE, PA 17013 Social Security #s 161-66-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738556 77834-L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760046 77834-L08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W _VS_ LAURA K. HAMILTON [ Note: see enclosed list of locations ] TERM, CASE NO: 07-5665 TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 06/12/2008 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 R1.60S 116-H COURT OF COMMON PLEAS THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 D$02-0395914 77834-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERO, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY CARLISLE REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE R1.60S 116-H DE02-0395914 77834-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OV CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAL_ ENTER (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 MER **** at The MCS Grog Inc 1601 Market Street, Suite 500, ]Fhia_ 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: S'T'EPHEN L BANKO JR ESO ADDRESS: 35101HRM .F ROAD _ CAMP H111 PA 17011 TELEPHONE: (25)_246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: j u • %F t, 2o6A Seal of the Court BY OURT: Pro notary/Cl sion Deputy 77834-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER PATHOLOGY DEPT 500 UNIVERSITY DR. HERSHEY. PA 17033 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all pathology reports and records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. MACRERETB 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: 161-66-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738ss8 77834-L08 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -vs- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, OR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760047 77834 -L09 COMMONWEALTH OF PSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE-OF INTENT TO SERVE A SUBPOENA TO PRODUCE DQCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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:.06/12/2008 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT CC: STEPHEN L. EANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H D802-0395914 77834-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY CARLISLE REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE R1.60S 116-H DE02-0395914 77834-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. VS. LAURA K. HAMILTON File No. 07-5665 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for_ CARLISLE REGIONAL HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group. Inc- 1601 Market Street, Suite 800 Phiiladelnlliia 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: STEPHEN L. BANKO. JR.. ES ADDRESS: 3510 TRINDLE ROAD TELEPHONE: (215 246-0900 SUPREME COURT ID #: ATTORNEY FOR: _ Defendant BY OURT: Pro notary/Cler D' 'sion Date: JL1-• 1g-- 266A Deputy Seal of the Court 77834-U9 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL HOSPITAL REHAB OPTIONS 417 VILLAGE DRIVE CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda,.handwritten notes, history and physical reports, x-ray films and reports, medication/prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : STACIR R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXE-%E-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738560 77834-LO9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760048 77834-LlO COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE.OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed,list of locations ) TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL. MCS on behalf of STEPHEN L. BANKO, JR., 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:i_f 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:.06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H DE02-0395914 77834-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY CARLISLE REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE R1.60S 116-H DE02-0395914 77834-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MIRA ORTHOPEDICS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS C= W, Inc.. 1601 Market Street Suite 800, P iladelplia, 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: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY URT: Pronotary/Cl i 6D-6ion. Deputy Date: ?. ?t" ?i ?L1p $ r Seal of the Court 77834-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MIRA ORTHOPEDICS 220 WILSON STREET MEDICAL ARTS BLDG CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and reports, medication/prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. MACRERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10 0738562 77834-L10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760049 77834-L11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACRERETH AND KELLY W. MACKERETH, H/W _VS_ LAURA K. HAMILTON [ Note: see enclosed.list of locations MCS'on behalf of STEPHEN L. BANKO., JR., ESQ. Attorney for DEFENDANT TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL. MCS on behalf.of STEPHEN L. BANKO, JR., 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 orderedat your expense by completing .the attached counsel card and returning same to-MCS or by contacting our local' MCS office. DATE:.06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 R1.60S 116-H COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103- (215) 246-0900 D802-0395914 77834-COI »> LOCATION. LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JQRGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL.CENTER PATHOLOGY CARLISLE.REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE . R1.60S 116-H COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for EMBARO (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 RID •R **** at The MCS C11M IM 1601 Market Street. Suite 800 Philade]pW& EA 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: STEPHEN L. BANKO. JR.. ESO. ADDRESS: 3510 TRiND E ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: t'om' ?e . ?ddO Seal of the Court BY THE URT: Proth otary/Cler Di ion Deputy Y' 77834-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EMBARQ 346 YORK ROAD CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : STACIE R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #s XXX-XX-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738564 77834-L11 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DR11-0760050 77834-L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W _VS_ LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed.list of locations ] TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL. MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to thin 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:.06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS'on behalf of STEPHEN L. RANKO,.JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.60S 116-H DE02-0395914 77834 -COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY CARLISLE REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE R1.60S 116-H DE02-0399914 77834-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DEPARTMENT OF WEL.FARF (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS ._mw- Inc.. 1601 Market Street, Suite 800, Phila&lplia, 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: STEPHEN L BANKO JR ESO ADDRESS: 3510 TRIND ROAD _CAMP HILL.. PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY 7EY UR Proth otary/Cl ivision JLw9- L M _ Deputy Date: Seal of the Court 77834-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DEPARTMENT OF WELFARE 1400 SPRING GARDEN STREET ROOM-601 PHILADELPHIA. PA 19130 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. WELFARE RECORDS INCLUDING ALL CASH ASSISTANCE, MEDICAL ASSISTANCE OR ANY OTHER BENEFIT APPLIED FOR OR RECEIVED BY MS. MACKERETH Dates Requested: up to and including the present. Subject : STACIR R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0739566 77834-L12 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 118-H DE11-0760051 77834-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACIUUUM AND KELLY W. MACK METH, H/W _VS_ LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE.OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed.list of locations I TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL . MCS on behalf of STEPHEN L. BANKO, JR., 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:.06/12/2008 CC: STEPHEN L. BANKO, JR., ESQ. 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS'on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103. (215) 246-0900 R1.60S 116-H DE02-0395914 77834-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED CHRISTOPHER J. BERG, M.D. MEDICAL RECORDS & XRAYS J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS & XRAYS CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY CARLISLE REGIONAL HOSPITAL MEDICAL RECORDS & XRAYS MIRA ORTHOPEDICS MEDICAL RECORDS & XRAYS EMBARQ EMPLOYMENT DEPARTMENT OF WELFARE WELFARE RECORDS SSA-DISABILITY DISABILITY FILE R1.60S 116-H D902-0395914 77834-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SSA-DISABILITY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, Inc- 1601 Market Street Suite 800_ P iladejUbiia_ 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: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRiNDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE C URT: Protho otary/Clerk, sion Date: Deputy Seal of the Court 77834-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SSA-DISABILITY 1234 MARKET ST. 20TH FL. PHILADELPHIA. PA 19103 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees. in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING DECISIONS, ORDERS, AWARDS OR ANY OTHER DOCUMENT RELATED TO SUCH CLAIM(s) Entire disability file, including but not limited to medical reports and /or records, claims, any and all correspondence, documentation supporting plaintiffs claim, applications, 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: up to and including the present. Subject : STACIE! R. MACRBRBTH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: 161-66-7489 Date of Birth: 08-10-1969 R1.60S 116-H SU10-0738568 77834-L13 r ?~. ,? _.,. .?' ?: , ,?? ?? r N CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS STACIE R. MACKERETH AND KELLY W. TERM, MACKERETH, H/W CUMBERLAND -VS- CASE NO: 07-5665 LAURA K. HAMILTON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/10/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.73 133-H DE11-0761388 77834-L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS STACIE R. MACKERETH AND KELLY W. TERM, MACKERETH, H/W -VS- CASE NO: 07-5665 LAURA K. HAMILTON NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PAUL H. MCCABE, M.D. MEDICAL RECORDS TO: MICHAEL SMITH, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 06/20/2008 MCS on behalf of CC: STEPHEN L. BANKO, JR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact MICHAEL SMITH, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 R1-60S 133-H STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0396559 77834-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PAUL H. MCCABE. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Gro. Inc.- 1601 Market Street, Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: 1215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY COURT: P othonot erlk viI Division 1 0 208 Deputy Date: je?19Tox Seal of the Court 77834-14 Jr V EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PAUL H. MCCABE, M.D. 2025 TECHNOLOGY PARKWAY SUITE 201 MECHANICSBURG, PA 17050 RE: 77834 STACIE R. MACKERETH 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: up to and including the present. Subject : STACIE R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1-60S 133-H SU10-0739430 77834-L14 ?? ? ?` ?,. ?' (, : '-e ; ;?w =? 'g :.? ? e- : CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/02/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.85 133-H DE11-0771405 77834-LlS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MOFFIT HEART & VASCULAR GROUP MEDICAL RECORDS KENNETH D. CONNER, MD MEDICAL RECORDS TO: LORIN ANDREW SNYDER, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 08/09/2008 CC: STEPHEN L. BANKO, OR., ESQ. - 28150.4-00066 Any questions regarding this matter, contact LORIN ANDREW SNYDER, ESQ. 28 S. PITT STREET CARLISLE, PA 17013 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.68S 133-H DE02-0400726 77834 -COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. VS. LAURA K. HAMILTON File No. 07-5665 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MOFFIT HEART & VASCULAR GROUP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group, Inc 1601 Market Street- Suite 800, Phil de phia_ 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: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID M ATTORNEY FOR: Defendant SEP 0 2 2008 Date: u..,&Af Seal of the Court BY THE COURT: /s, le Prothonotary/Clerk, Civil vision ? ktAl-' IF 10 D t 77834-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MOFFIT HEART & VASCULAR GROUP 360 ALEXANDER SPRING ROAD CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH 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: up to and including the present. Subject : STACIE R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.68S 133-H SU10-0746298 77834-LlS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Y ' STACIE R. MACKERETH AND KELLY W. File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KENNETH D. CONNER- MD (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MC Gm=. Inc-- 1601 Market Street Suite 800 Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: -STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD I , _ CAMP ULL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SEP 0 2 2008 Date: ?, ?lrpg Seal of the Court BY THE COURTS&Z, .r/C. - r onotary/Clerk, Civil D6ision Q. Deput 77834-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KENNETH D. CONNER, MD 207 HOUSE AVE. CAMP HILL, AP 17011 RE: 77834 STACIE R. MACKERETH 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: up to and including the present. Subject STACIE R. MACKERETH . 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.68S 133-H SU10-0746300 77834-L16 C K'im' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/10/2009 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R2.07 133-H DE11-0863294 77834-L17 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MASLAND ASSOCIATES, INC. MEDICAL RECORDS TO: LORIN ANDREW SNYDER, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 02/16/2009 CC: STEPHEN L. BANKO, JR., ESQ. LORIN ANDREW SNYDER, ESQ. TURO LAW FIRM 28 S. PITT STREET CARLISLE, PA 17013 28150.4-00066 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.81S 133-H DE02-0473271 77834-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W VS. LAURA K. HAMILTON File No. 07-5665 TO: Custodian of Records for MAST ND ASSOCIATES TNC' (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: * * * * S F ATTACHED RIDER * * * * at The MCS Croup,, Inc„ 1601 Market Street, Suite 800, Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: 4TFPH L BANKO JR ESQ ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 10 2009 v Date: rya °? Seal of the Court BY COURT: Pr onotgr i Division Deputy 77834-17 + EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MASLAND ASSOCIATES, INC. 220 WILSON STREET SUITE 109 CARLISLE, PA 17013 RE: 77834 STACIE R. MACKERETH 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: up to and including the present. Subject : STACIE R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.81S 133-H SU10-0772896 77834-L17 C-` ? L:` ? ?? "?'1 _... ?`-` ? ---s i _. Ear. _? "T7 ?+s? _.. ?? ? ? i . ?.' ?. { CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-5665 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/20/2009 MCS on behalf of /S/ Steel n oC. 12anho, r., C-S?. STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.83S 133-H DEl1-0889156 77834-L18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON - 28150.4-00066 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SHERMANSDALE FAMILY PRACTICE MEDICAL RECORDS TO: LORIN ANDREW SNYDER, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., 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: 03/29/2009 CC: STEPHEN L. BANKO, JR., ESQ. LORIN ANDREW SNYDER, ESQ. TURO LAW FIRM 28 S. PITT STREET CARLISLE, PA 17013 COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.83S 133-H DE02-0492344 77834-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W File No. 07-5665 VS. LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for S iSDALE FAMILY PRACTICE C/O SPRING ROAD FAX. PRACT. (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: **** 4E ATTACHED RIDER **** at The MC5 Ca= Inc 1601 Market Street Suite 800 Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. RANKO. JR.. ESQ. ADDRESS: 3510 TRIM LE ROAD CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 'AM 2 0 2009 Date: Seal of the Court BY THE COURT: Z, sl-4, r.-k- gin Prothonotary/Clerk, Civil Divisi D ty 77834-10 EXPLANATION OF REQUIRED, RECORDS TO: CUSTODIAN OF RECORDS FOR: SHERMANSDALE FAMILY PRACTICE C/O SPRING ROAD FAM PRACT 1921 SPRING ROAD CARLISLE. PA 17013 RE: 77834 STACIE R. MACKERETH 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: up to and including the present. Subject : STACIE R. MACKERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Birth: 08-10-1969 R1.83S 133-H SU10-0779216 77834-L18 FILE OF THE 2069 APR 21 Pd :7 16 L PRAECIPE FOR LI„§TING CASE FOR TRIAL (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ?X for JURY trial at the next term of civil court. ? for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) STACIE R. MACKERETH and KELLY W. MACKERETH, h/w (other) VS. LAURA K. HAMILTON VS. (Plaintiff) (Defendant) The trial list will be called on 01/05/2010 and Trials commence on 01/13/2010 Pretrials will be held on (Briefs are due 5 days before pretrials 5665 2007 No. Term Indicate the attorney who will try case for the party who files this praecipe: Stephen L. Banko, Jr./Attomey for Defendant Indicate trial counsel for other parties if known: Lorin Andrew Snyder, Esquire/Attorney for Plaintiffs This case is ready for trial. November 5, 2009 Date: Print Name: Attorney for: Defendant (check one) ?X Civil Action - Law ? Appeal from arbitration Jr. CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid and addressed as follows: Lorin Andrew Snyder, Esquire Turo Law Office 28 South Pitt Street Carlisle, PA 17013 MARGOLIS EDELSTEIN By. Angela elly, Secretary Date: November 5, 2009 ea/1.- 2009 PT V 10 PH 12: I 5.00 Po CK.* 31 03 a53:5 STACIE R. MACKERETH, and : IN THE COURT OF COMMON PLEAS OF KELLY W. MACKERETH, Husband : CUMBERLAND COUNTY, PENNSYLVANIA and Wife, Plaintiffs, V. : NO. 07 - 5665 CIVIL TERM LAURA K. HAMILTON, Defendant. : CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Turo Law Offices, counsel for the Plaintiffs in the above-captioned action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is $50,000.00. The counterclaim of the Defendants in the action is: N/A. The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Stephen L. Banko, Jr., Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, 18131/09 Date TURO LAW OFFICES Lorin A rew Zn--y i PA I [??g 203199 28 S itt Stre Carlisle, PA 17013 717-245-9688 Attomey for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition for Appointment of Arbitrators upon the following by depositing the same in the United States Mail, first class, postage pre-paid, and by facsimile at 717-975-8124 on the Thirty-First day of December, 2009, from Carlisle, Pennsylvania, addressed as follows: Stephen L. Banko, Jr., Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 TURO LAW OFFICES LorVuthl rew Sn r?Esq. 28 Pit t Street/ Car isle, PA 1701,,'Y (71 Attorney for Plaintiffs 209 DEC 3 1 AM f l 57 Cl! P ?dsh e*? #8 STACIE R. MACKERETH AND IN THE COURT OF COMMON PLEAS OF KELLY W. MACKERETH, H/W, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION - LAW v LAURA K. HAMILTON, Defendant 07-5665 CIVIL TERM IN RE: CASE STRICKEN FROM LIST ORDER OF COURT AND NOW, this 5th day of January, 2010, upon consideration of the call of the civil trial list, and no person having appeared to call the above-captioned case for trial, it is stricken from the trial list. .-Zorin Andrew Snyder, Esquire Turo Law Office 28 South Pitt Street Carlisle, PA 17013 For Plaintiffs Stephen L. Banko, Jr., Esquire 3510 Trindle Road Camp Hill, PA 17011 For Defendant Court Administrator - f'tacv_`L i.J +tL :mae Cod ;s -rut Lc /A?115 c? eo :?? r?tl ?- Ntic o?ot By the Court, Ii f STACIE R. MACKERETH, and KELLY W. MACKERETH, Husband and Wife, Plaintiffs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURA K. HAMILTON, Defendant. NO. 07 - 5665 CIVIL ACTION - LAW CIVIL TERM ORDER OF COURT AND NOW, this day of 2010, in consideration of the foregoing petition, 6A.W4t 2A?? , Esq.,. f? Es q., and 2LLCk4zL z_ 4'1& ' Esq., are appointed arbitrators in the above-captioned action as prayed for. By the Court, ko - Qo I ES m?? C N q t? t `- r `l = co Stacie R. Mackereth & Kelly W. Mackereth, Husband and Wife, Plaintiffs Laura K. Hamilton, Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 07-5665 Civil Action - Law Oath e do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United S ates and the Constitution of this Commonwealth and that we will discharge the duties of our office wi fi elity. S gna igna a Si nature Bert C. Saidis Es q. Stephen Tiley. Esq. Michael Travis Esq. ame (Chairman) Name Name S idis Flower & Lindsay Frey & Tile w Firm Law Firm Law Firm 2 West Hi 2h Street 5 South Hanover Street 3904 Trindle Road ddress Address Address arlisle PA 17013 Carlisle PA 17013 Ca Hill PA 17011-4246 ity, zip city, zip City, Zip Award e, the undersigned arbitrators, having been duly appointed and sworn (or `affirmed), make the followh ward: (Note: If damages for delay are awarded, they shall be separately stated) Nt r/N? 4AI r'J-400 P- ®Y -7-'[ & eL 1A.) T!Pe- 1?,S /V (" j w9 S 3 M" t= i? 1F E A u fArbitrbitr issents (Insert name if applicable) Pate of Hearing: February 17, 2010 Robert C. Saidis (Chairman) Date of Award: 'y 3 2?lQ s Mica-el Travis Notice of Entry of Award th ig Now, the ,&??day of J - , 2010, at 2,',? 7 ,;.M., the above award was entered n the docket and notice th eof given by-Mail to the parties or their attorneys. itratocompensation to be paid upor. appeal; $..3.$?(,S, pd By: Deputy C,°Pt tiS ?y f e s ?,v =mil IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STACIE R. MACKERETH and KELLY W. MACKERETH, husband and wife, Plaintiffs V. LAURA K. HAMILTON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 07-5665 JURY TRIAL DEMANDED NOTICE OF APPEAL m 0 Mr X3.- f=, ? Z3 r? c ? %C -c FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is hereby given that Defendant Laura K. Hamilton appeals the award of the board of arbitrators entered in this case on April 14, 2010. A jury trial is demanded ? . (Check the line if a jury trial is demanded. Otherwise jury trial is waived.) I hereby certify that (1) the compensation of the arbitrators has been paid, or (2) . (Strike out the inapplicable clause) L. Banko, Jr. for Defendant/Appellant Note: the demand for a jury trial on appeal from compulsory arbitration is governed by Rule 1007.1(b). (b) No affidavit or verification is required. Adopted March 16, 1981, effective May 15, 1981 s 3 S-6. 06 P -t 6dvrll e ca.'t -"y Crs'4Ifyeo .a-s S -y D. 6() cash a fS?,kv 0 ?. yl KK I' iw ALEC, rJ, t ?L THE 2010 HAY 14 PK 3: `L2 C1 !k Nly Attorney for Defendant STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 PHONE: 717-760-7501 FAX: 717-975-8124 EMAIL: sbanko@margolisedelstein.com STACIE R. MACKERETH and KELLY W. MACKERETH, husband and wife, Plaintiffs V. LAURA K. HAMILTON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 07-5665 JURY TRIAL DEMANDED PROOF OF SERVICE The undersigned hereby certifies that a true and correct copy of the Notice of Appeal of Arbitrators' Award of Defendant, Laura K. Hamilton, was served upon the person and in the manner indicated below: Lorin Andrew Snyder, Esquire Turo Law Office 28 South Pitt Street Carlisle, PA 17013 DELSTEIN Stepfiffi L. B nko, Jr., Esquire Attorney No 41727 Counsel fo Defendant Date: May 13, 2010 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Proof of Service upon counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, and addressed as follows: Lorin Andrew Snyder, Esquire Turo Law Office 28 South Pitt Street Carlisle, PA 17013 MARGOLIS EDELSTEIN Angela A. II Secretary to Stephen L. Banko, Jr. Date: May 13, 2010 ~' ~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA ~' /'~' PURSUANT TO RULE 4009.22 V ~~~ IN THE MATTER OF: COURT OF COMMON PLEAS STACIE R. MACKERETH AND KELLY W. TERM, MACKERETH, H/W CUMBERLAND -VS- CASE NO: 07-5665 LAURA K. HAMILTON N C_ ~ y As a prerequisite to service of a subpoena for documents and things~gi~Y'su~ ~ to Rule 4009.22 ~~~ C:, `, _ .iT; ~+.J ' l ~; ~~, r .` ti MCS on behalf of STEPHEN L. BANKO, JR., ESQ. ` [..~ ~'" certifies that,,,,`,- c, -- -<' (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 seared, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 06/15/2010 / S / ~te~herc oC . (/~arc~oi r. , ~~~.. STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.95S 133-H DE11-1111732 77834-L19 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: STACIE R. MACKERETH AND KELLY W. MACKERETH, H/W -VS- LAURA K. HAMILTON COURT OF COMMON PLEAS TERM, CASE NO: 07-5665 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 METLIFE AUTO & HOME INSURANCE TO: LORIN ANDREW SNYDER, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/24/2010 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT CC: STEPHEN L. BANKO, JR., ESQ LORIN ANDREW SNYDER, ESQ. TURD LAW FIRM 28 S. PITT STREET CARLISLE, PA 17013 - 28150.4-00066 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.95S 133-H DE02-0665206 77834-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STACIE R. MACKERETH AND KELLY W. vs. File No. 07-5665 LAURA K. HAMILTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for_ METLIFE AUTO & HOMF. (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 iDER **** at The MGS Groun_ Lnc__ 1601 M rket .tree _ ~i .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: _$TEPHEN L. BANKO. JR.. ESO ADDRESS: 3510 TRiNDi.F. ROAD ~AN1P HILL_ PA 17011 TELEPHONE:1~1246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant `~, gi~pp{{ Date: `~Q~ Q,/ Seal of the Court BY THE COURT: ~~ r thonotarylClerk, Civil Division eputy 77834-19 •- EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: METLIFE AUTO & HOME MAIL PROCESSING CTR P.O. BOX 410200 CHARLOTTE, NC 282410200 RE: 77834 STACIE R. MACKERETH Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. DATE OF LOSS: 10/2/05 AND METLIFE CLAIM# WFB85495 NB. 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: up to aad including the present. Subject STACIE R. MACRERETH 801 PINE ROAD, CARLISLE, PA 17013 Social Security #: XXX-XX-7489 Date of Sirth: 08-10-1969 Date of Loss: 10/02/2005 R1.95S 133-H SU10-0846236 77834-L19 STACIE R. MACKERETH, and KELLY W. MACKERETH, Husband and Wife, Plaintiffs, V. LAURA K. HAMILTON, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 5665 CIVIL TERM : CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please settle, withdraw and discontinue the above-captioned matter on behalf of the Plaintiffs, with prejudice. Respectfully submitted, TURO ROBINSON I1 a9- 1o Date Lorin An w der, S"y PA 164 03199 129 S Pitt Street Carli PA 717-245-9688 Attomey for Plaintiffs C-D c © -'? _ax 0 --r x CAr, N, ?fm 2.p = cl-nn :x C3r rn --? w a