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HomeMy WebLinkAbout07-6904IV A MICHELE C. NATALE, 240 Minnich Road Mechanicsburg, PA 17021 Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ?7'CegDy ??v?' BRICE D. ARNDT, D.D.S DENTAL MALPRACTICE 3975 Trindle Road Camp Hill, PA 17011, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. Writ of Summons shall be issued and forwarded to ( ) Attorney ( X ) Sheriff. Jeffrev T. McGuire. Esquire Attorney I.D. No. 73615 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Names/Address/Telephone No. WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN AC TN AGAIN YOU. Prothonotary Date: olaa7 by Deputy 07439-001/125076 / Date: 1111011 C^? j v ra ca EJi w 0 -n F 7 cp C?3 t7 ? SHERIFF'S RETURN - REGULAR CASE NO: 2007-06904 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATALE MICHELE C VS ARNDT BRICE D DDS KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon ARNDT BRICE D DDS the DEFENDANT , at 1719:00 HOURS, on the 6th day of December-, 2007 at 3975 TRINDLE ROAD CAMP HILL, PA 17011 by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge lx/l-7/b7 4- 18.00 14.40 .00 10.00 .00 'V 42.40 So Answers: R. Thomas Kline 12/07/2007 CALDWELL " K "' RNS Sworn and Subscibed to By: before me this day of A.D. THOMAS, THOMAS & HAFER, LLP Evan Black. Esquire Attorney I.D. 17884 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 441-7051 Attornevs for Defendant MICHELE C. NATALE, Plaintiff V. BRICE D. ARNDT, DDS, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6904 CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Kindly enter the appearance of Evan Black, Esquire on behalf of the Defendant, Brice Arndt, DDS, relative to the above-captioned action. Respectfully submitted, Thomas, Thomas & Hafer, LLP Date: 9 a e By: `-/ Evan Black, ,squire Attorney I.D. 17884 Thomas, Thomas and Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 441-7051 Attorneys for Defendant CERTIFICATE OF SERVICE 1, Joan L. Wolfe, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg. Pennsylvania addressed as follows: Jeffrey T. McGuire, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 THOMAS, THOMAS & HAFER, LLP Date: " Ue, )tck- Joar(q. Wolfe Tt FiLE# r- Cii; r:I'll r V 2009 SEP 15 N 2: 0 4 V W THOMAS, THOMAS & HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 441-7051 Attorneys for Defendant MICHELE C. NATALE, Plaintiff V. BRICE D. ARNDT, DDS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6904 CIVIL ACTION -LAW JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES PRAECIPE AND RULE TO FILE COMPLAINT TO THE PROTHONOTARY OF SAID COURT: Please issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days after service of the Rule or suffer a judgment of non pros. Respectfully submitted, Thomas, Thomas & Hafer, LLP Date: By: 4,.,ejK Evan Black, Esquire Attorney I.D. 17884 Thomas, Thomas and Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17] 08 (717) 441-7051 Attorneys for Defendant CERTIFICATE OF SERVICE I, Joan L. Wolfe, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Jeffrey T. McGuire, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 THOMAS, THOMAS & HAFER, LLP Date: ' 2q -01 J L. Wolfe ?; 2` M','i iw MICHELE C. NATALE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. : NO. 07-6904 BRICE D. ARNDT, DDS, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES RULE TO FILE COMPLAINT TO: Michelle C. Natale, Plaintiff c/o Jeffrey T. McGuire, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 You are hereby directed to file a Complaint against Defendant, Brice D. Arndt, DDS, within twenty (20) days or non pros seq. reg. DATE: 9?a9/09 rothonot n CP; MICHELE A. NATALE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No.: 07-6904 BRICE D. ARNDT, DDS, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR 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 1-800-990-9108 717-249-3166 MICHELE A. NATALE, Plaintiff V. BRICE D. ARNDT, DDS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 07-6904 CIVIL ACTION -LAW JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES COMPLAINT AND NOW, comes the Plaintiff, Michele A. Natale, by and through her attorneys, Caldwell & Kearns, and files the within Complaint; and in support thereof avers the following: 1. Plaintiff Michele A. Natale (hereinafter "Plaintiff') is an adult individual residing at 240 Minnich Road, Chambersburg, Franklin County, Pennsylvania. 2. Defendant Brice D. Arndt, DDS (hereinafter "Defendant Arndt") is an adult individual, and at all times relevant hereto was a licensed medical practitioner purporting to specialize in dental services, providing dental care to the public as a principal, agent, servant or employee of Family Dentistry, with an office at 3975 Trindle Road, Camp Hill, Cumberland County, Pennsylvania. 3. On August 15, 2002, Defendant Arndt performed root canal therapy on Plaintiff's tooth #3. 4. On August 23, 2002, Defendant Arndt performed an apiocoectomy and oro-antral fistula closure on Plaintiff s tooth #3. 5. On November 4, 2002, Defendant Arndt performed additional endodontic treatment on Plaintiff s tooth #3. 6. In or about December 2002, Defendant Arndt removed the existing, temporary crown on Plaintiff s tooth #3. 7. On January 9, 2003, Defendant Arndt performed additional endodontic treatment on Plaintiff s tooth #3. 8. On January 28, 2003, Defendant Arndt placed a permanent crown on Plaintiffs tooth #3. 9. On October 25, 2006, Plaintiff was diagnosed by Dr. Nicole M. Yingling (hereinafter "Dr. Yingling") with acute apical periodontitis as a result of obturation of the mesiobuccal 2 (MB2), root fracture and/or perforation of Plaintiff s tooth #3. 10. On October 31, 2006, Dr. Yingling performed endodontic re-treatment on Plaintiff s tooth #3. 11. The endodontic re-treatment initiated on Plaintiff's tooth #3 on the aforesaid date required the removal of plastic carrier based obturators from mesiobuccal 1 (MB 1) and MB2. 12. Upon removal of the plastic carrier based obturators on the aforesaid date, it was revealed that MB2 had been previously instrumented; however not instrumented to length. 13. As a result of the short obturations and perforation in tooth #3, Plaintiff experienced pain over a long period of time and will require long-term, consistent monitoring and further treatment. 14. At some time prior to October, 2006, Defendant Arndt performed endodontic treatment, purportedly root canal therapy, on Plaintiff's tooth #31. 15. On October 25, 2006, Plaintiff presented to Dr. Yingling complaining of pain the in the lower right area of her jaw. 16. On the aforesaid date, upon examination and the performance of diagnostic tests by Dr. Yingling, it was revealed that the obturation in Plaintiff s tooth #31 was short in the D root, and approximately 3 mm short in the mesial root. 17. As a result of the short obturations in tooth #31, Plaintiff experienced pain over a long period of time and will require long-term, consistent monitoring and further treatment since tooth #31 is at an increased risk for chronic infection. 18. On February 7, 2006, Defendant Arndt performed root canal therapy on Plaintiff's tooth # 18. 19. On February 16, 2006, Defendant Arndt completed root canal therapy on Plaintiff's tooth #18. 20. On March 10, 2006, Plaintiff presented to Endodontic Associates complaining of sensitivity and pain. 21. On the aforesaid date, Endodontic Associated diagnosed Plaintiff as having a separated instrument in tooth # 18. 22. In or about April, 2006, Plaintiff complained to Defendant Arndt of pain and discomfort in Plaintiff's tooth #18. 23. In response to Plaintiff's complaints of tooth #18, Defendant Arndt readjusted the crown on the aforesaid date; however, it is averred that Defendant Arndt never informed Plaintiff of the cause of Plaintiff's pain and discomfort, nor did Defendant Arndt perform appropriate follow-up exams, surgical treatment or extraction on tooth #18. 24. On November 7, 2006, Plaintiff presented to Dr. Yingling with complaints of tenderness to tooth # 18. 25. On the aforesaid date, Plaintiff was diagnosed by Dr. Yingling with acute apical periodontitis in tooth #18. 26. On the aforesaid date, Plaintiff had radiographs performed by Dr. Yingling, which revealed a separated instrument in the mesial root, with a possible lucency in Plaintiff s tooth #18. 27. On June 8, 2007, Dr. Joseph Foote performed a debridement on Plaintiff's tooth #18, as Dr. Foote noted a questionable piece of material found in the gum area. 28. In or about August, 2007, as a result of constant pain and high risk of perforation with re-treatment, Plaintiff's tooth #18 was extracted. 29. As a result of the extraction of Plaintiff's tooth #18 due to the presence of a broken instrument in the root of tooth #18, radiographs performed by Dr. Yingling on October 5, 2007 revealed that Plaintiff's tooth #17 had migrated, causing Plaintiff additional pain. 30. As a result of the presence of a broken instrument in the root of tooth #18, Plaintiff has suffered constant pain and discomfort, loss of tooth #18, possible additional tooth extractions, all requiring long-term, consistent monitoring and further treatment. 31. On May 15, 2001, Dr. Arndt performed endodontic treatment, including crown adjustments to Plaintiff's #20. 32. On June 13, 2001, Defendant Arndt performed endodontic treatment, purportedly root canal therapy and/or crown adjustments, on Plaintiff's tooth #20. 33. On November 7, 2006, Plaintiff presented to Dr. Yingling with complaints of tenderness to tooth #20. 34. On the aforesaid date, Plaintiff was diagnosed by Dr. Yingling with acute apical periodontitis in tooth #20 as a result of a void in the obturation. 35. On the aforesaid date, Dr. Yingling recommended endodontic re-treatment of Plaintiff's tooth #20. 36. On November 13, 2006, Dr. Yingling performed the first part of a two-phase endodontic re-treatment on Plaintiff s tooth #20. 37. On November 22, 2006, Dr. Yingling performed the second part of endodontic re- treatment on Plaintiff's tooth #20. 38. As a result of the void in the obturation in Plaintiff's tooth #20, Plaintiff experienced chronic pain and discomfort until endodontic re-treatment was performed by Dr. Yingling. COUNT I - NEGLIGENCE 39. Paragraphs 1 through 38 are incorporated herein by reference as though fully set forth. 40. Defendant Arndt holds himself out to be a dental practitioner and dental healthcare provider who possesses skill and knowledge in his specialty, and holds himself out to public as so qualified. 41. Defendant Arndt failed to exercise the judgment and skill of a reasonable dentist in his treatment of Plaintiff, under the following circumstances: a. failure to use good judgment in the treatment and care of Plaintiff as it pertains to the performance of endodontic procedures; b. failure to engage the assistance of a skilled practitioner in performing endodontic procedures, and in follow-up care; C. failure to adequately evaluate Plaintiff's teeth, assess the degree of difficulty associated with treatment, assess his own degree/level of skill, then determine whether to refer Plaintiff to a specialist for treatment of Plaintiff's teeth #3, 31, 18 and 20; d. failure to diagnose Plaintiff's symptoms associated with teeth #3, 31, 18 and 20, and refer Plainitff to a specialist for further treatment; e. failure to properly perform root canal therapy, resulting in substandard obturation of MB2, root fracture and/or perforation of Plaintiff's tooth #3; f. failure to properly perform root canal therapy on Plaintiff's tooth #3, resulting in persistent periapical disease; g. failure to properly perform root canal therapy on Plaintiff's tooth #3, resulting in pain and discomfort to the Plaintiff over a prolonged period of time; h. failure to properly perform endodontic therapy, purportedly root canal therapy, resulting in the obturation of the D root and approximately 3 mm short obturation in the mesial root of Plaintiff's tooth #31; i. failure to properly perform endodontic therapy, purportedly root canal therapy on Plaintiff's tooth #31, resulting in persistent pain and discomfort; failure to properly perform endodontic therapy, purportedly root canal therapy on Plaintiff's tooth #31, resulting in an increased risk of chronic infection; k. failure to properly perform root canal therapy on Plaintiff's tooth #18, resulting in persistent and chronic pain and discomfort; failure to properly perform root canal therapy on Plaintiff's tooth # 18, resulting in apical periodontitis; m. failure to properly perform root canal therapy on Plaintiff's tooth # 18, resulting in the presence of a separated instrument in the root of Plaintiff's tooth #18; n. failure to properly diagnosis the existence of a separated instrument in the root of Plaintiff's tooth # 18; o. failure to properly perform follow up exams on Plaintiff as a result of the presence of a separated instrument in the root of Plaintiff's tooth # 18; P. failure to properly treat, including surgical procedures or extraction, the presence of a separated instrument in the root of Plaintiff's tooth # 18; q. failure to advise the Plaintiff of the presence of a separated instrument in the root of tooth #18; r. failure to properly perform root canal therapy on Plaintiff's tooth # 18, resulting in additional dental procedures, including the eventual extraction and loss of tooth #18, as re-treatment posed a high risk of perforation; S. failure to properly perform root canal therapy on Plaintiff's tooth #18, resulting in the migration of tooth #17, and extraction of tooth #17; t. failure to properly perform endodontic treatment, purportedly root canal therapy, on Plaintiff's tooth 920, resulting in persistent and chronic pain and discomfort; U. failure to properly perform endodontic therapy, purportedly root canal therapy on Plaintiff's tooth #20, resulting in apical periodontitis; V. failure to properly perform endodontic therapy, purportedly root canal therapy on Plaintiff's tooth #20, resulting in a void in the root canal obturation; W. failure to properly perform endodontic therapy, purportedly root canal therapy on Plaintiff's tooth #20, resulting in additional re-treatment in two-phases for Plaintiff; X. failure to diagnose and properly respond to signs and symptoms exhibited by Plaintiff, indicative of complications of root canal therapy and endodontic treatment; Y. failure to ensure adequate post-treatment care of Plaintiff as described herein; Z. holding out expertise to the public which induced the Plaintiff to believe that adequate, proper and reasonable care would be provided when, in fact, adequate, proper and reasonable care was not provided to Plaintiff as described herein; and aa. failure to exercise reasonable care and diligence in the application of knowledge and skill to the Plaintiff's case as it pertains to the appropriate endodontic treatment, including root canal therapy, properly performed endodontic treatment, including root canal therapy, and reasonable and adequate post-treatment care. 42. As a direct and proximate cause of the conduct set forth in the aforementioned paragraph, Plaintiff has suffered and will continue to suffer the following damages: a. extreme pain and suffering; b. additional corrective dental procedures; C. loss of additional teeth due to required extractions; d. nerve damage; e, increased risk of chronic infection; f. extensive medical bills; g. future medical treatment; h. lost income; and mental anguish, humiliation, embarrassment, distress and other damages as allowed by law. WHEREFORE, Plaintiff Michele A. Natale respectfully requests this Honorable Court to enter judgment on her behalf and against Defendant Brice D. Arndt, D.D.S. in an amount in excess of Fifty Thousand ($50,000.00) Dollars together with interests and costs thereon as allowed by law. COUNT II - LACK OF INFORMED CONSENT 43. Paragraphs 1 through 42 are incorporated herein by reference as though fully set forth. 44. Defendant Arndt did not obtain proper informed consent of Plaintiff prior to performing any endodontic procedures as described herein. 45. Defendant Arndt failed to give Plaintiff sufficient information relevant to the dental procedures, their risks, and their possible complications, that a reasonable person in the Plaintiff's position would have considered significant in deciding whether to have the endodontic procedures as descried herein performed. 46. As a direct and proximate result of the dental procedures Defendant Arndt performed on Plaintiff without her informed consent, Plaintiff has suffered and will continue to suffer damages as aforesaid. WHEREFORE, Plaintiff Michele A. Natale respectfully requests this Honorable Court to enter judgment on her behalf and against Defendant Brice D. Arndt, D.D.S. in an amount in excess of Fifty Thousand ($50,000.00) Dollars together with interests and costs thereon as allowed by law. Dated: / 01301 6 5 By: Mc,96ire, Esquire I.D. No. 73617 3631 North Front Street Harrisburg, PA 17110 (717)-232-7661 Attorney for the Plaintiff VERIFICATION I verify that the averments in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unworn falsification to authorities. Michele A. Natale 07439-0011154926 CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the within document this 30h? day of L,-ro0" , 2009, on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Evan Black, Esquire THOMAS, THOMAS & HAFER LLP 305 North Front Street, Sixth Floor P. O. Box 999 Harrisburg, PA 17108 CALDWELL & KEARNS By: 07439-001/154926 RILED-3.1 l-'ClE ELF THE F'R" .`" CTARY 2009 NOY -2 F 1: 15 MICHELE A. NATALE, Plaintiff V. BRICE D. ARNDT, DDS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No.: 07-6904 CIVIL ACTION -LAW JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES CERTIFICATE OF MERIT PURSUANT TO PA. R.C.P. 10412.3 OF PLAINTIFF MICHELE A. NATALE AGAINST DEFENDANT BRICE D. ARNDT. DDS I, Jeffrey T. McGuire, Esquire, certify that: An appropriate licensed professional has supplied a written statement that there exists a reasonable probability that the care, skill or knowledge exercised by Defendant Brice D. Arndt, DDs and/or exhibited in the treatment, practice or work that is the subject of the Complaint, fell outside acceptable professional standards and that onduct was a cause in bringing about the harms as specifically identified in Plaintiff's ompl nt. Date: October3 ? 2009 By: V6331 cGuiy6, Esquire I.D. N 73617 ll & Kearns orth Front Street Harrisburg, PA 17110 (717) 232-7661 Fax (717) 232-2766 Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this 2A day of Oe,Yp 69- (2 , 2009, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Evan Black, Esquire THOMAS, THOMAS & HAFER LLP 305 North Front Street, Sixth Floor P. O. Box 999 Harrisburg, PA 17108 CALDWELL & KEARNS BY: l'lt-?vla 07439-001/155027 FILr,'L"I-? f CF THE FIF-c 2009 NOV -2 PH 1 16 THOMAS, THOMAS & HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 eblackp_tthlaw.com Richard S. Wade, Esquire Attorney I.D. 209843 rwade&tthlaw.com 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 441-7051 Attorneys for Defendant Brice D. Arndt, DDS. MICHELE C. NATALE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. : NO. 07-6904 BRICE D. ARNDT, DDS, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES NOTICE TO PLEAD TO: Michele C. Natale, Plaintiff c/o Jeffrey T. McGuire, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-153 You are hereby notified to plead in response to the attached Preliminary Objections to Defendants' Joinder Complaint within twenty (20) days of service hereof or the relief requested may be entered against you. THOMAS, TH & ER, By: an Black, Esquire Attorney I.D. No. 17884 Richard S. Wade, Esquire Attorney I.D. No. 209843 THOMAS, THOMAS & HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 eblackgtthlaw.com Richard S. Wade, Esquire Attorney I.D. 209843 rwade(a?tthlaw.com 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 441-7051 Attorneys for Defendant Brice D. Arndt, DDS. MICHELE C. NATALE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. : NO. 07-6904 BRICE D. ARNDT, DDS, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES PRELIMINARY OBJECTIONS OF DEFENDANT BRICE D. ARNDT, DDS. TO PLAINTIFF'S COMPLAINT AND NOW, come Defendant Brice D. Arndt, DDS. ("Dr. Arndt") by and through his counsel, Thomas, Thomas & Hafer, LLP, and respectfully submits the following Preliminary Objections to Plaintiff's Complaint: 1. Plaintiff, Michelle Natale, ("Plaintiff') initiated this professional liability matter by the filing of a Writ of Summons and, later, by the filing of a Complaint on or about November 2, 2009 ("Complaint"). 2. In Plaintiff s Complaint, it is generally alleged that Dr. Arndt provided negligent dental care to Plaintiff. 3. It is further generally alleged that Dr. Arndt failed to properly inform Plaintiff of the risk associated with the dental procedures performed. 4. Pennsylvania Rule of Civil Procedure (hereinafter "Rule") 1028(a)(2) provides that a party may file preliminary objections when a pleading fails "to conform to law or rule of court" or includes "scandalous or impertinent matter." Pa.R.C.P. No. 1028(a)(2). 5. In addition, Rule 1028(a)(3) allows a party to preliminarily object to a pleading due to "insufficient specificity in a pleading." Pa.R.C.P. No. 1028(a)(3). 6. Rule 1019(a) further provides that "[t]he material facts on which a cause of action or defense is based shall be stated in a concise and summary form." Pa.R.C.P. No. 1019(a). 7. Accordingly, Defendant respectfully raises the following Preliminary Objection to Plaintiff s Complaint: PRELIMINARY OBJECTION IN THE NATURE OF A MOTION TO STRIKE VAGUE AND OVERLY BROAD ALLEGATIONS OF NEGLIGENCE CONTAINED IN SEVERAL SUBPARAGRAPHS OF PARAGRAPH 37 PURSUANT TO Pa.R.C.P. 10 1 9(a) AND 1028(a)(3) FOR LACK OF SPECIFICITY. 8. Paragraphs 1 through 7 are incorporated by reference as though set forth at length herein pursuant to Pa.R.C.P. 1019(g). 9. Paragraph 41 of Plaintiffs' Complaint contains several subparagraphs which contain vague and overly broad allegations of negligent conduct which is attributed by Plaintiff to Moving Defendants. 10. Specifically, Plaintiff improperly asserts overly broad and vague allegations of negligence in paragraph 41 and subparagraphs (a), (b), (c), (d), (e), (f), (g), (h), (i), 0), (k), (1), (m), (n), (o), (p), (q), (r), (s), (t), (u), (v), (w), (x), (y), (z) and (aa) of Paragraph 41 of Plaintiff's Complaint. 11. Paragraph 41 and the above subparagraphs violate the Pennsylvania Rules of Civil Procedure and supporting case law because they are little more than boilerplate allegations of negligence which are not supported by factual averments. 2 12. Paragraph 41 and the above subparagraphs constitute nothing more that mere "notice pleading" which the Pennsylvania legislature has clearly rejected in adopting a requirement of "fact pleading" in Rules 1019(a) and 1028(a)(3). Pa.R.C.P. No. 1019(a) and No. 1028(a)(3); Sevin v. Kelshaw, 611 A.2d 1232 (Pa. Super. 1992). 13. To satisfy the requirements of Rules 1019(a) the allegations in a complaint must (1) notify the defendant of what plaintiffs claim is and the grounds upon which it rests, and (2) formulate the issue by summarizing those facts essential to support the claim. Baker v. Rangos, 324 A.2d 498 (Pa. Super. 1974). 14. As the Pennsylvania Superior Court explained in Estate of Swift v. Northeastern Hosp. of Phila., 690 A.2d 719 (Pa. Super.), appeal denied, 701 A.2d 577 (Pa. 1997), "while it is not necessary that the complaint identify the specific legal theory of the underlying claim, it must apprise the defendant of the claim being asserted and summarize the essential facts to support the claim." 15. The Pennsylvania Supreme Court has also emphasized the paramount importance of preliminary objections to the factual specificity of a complaint in the often cited case of Connor v. Allegheny General Hosp., 461 A.2d 600 (Pa. 1983). 16. Paragraph 41 and the above subparagraphs are insufficient in that they fail to adequately apprise Moving Defendants of the factual basis of the tortious conduct that Plaintiff asserts. Id. 17. Courts of Common Pleas throughout this Commonwealth have stricken averments of negligence of the sort contained in Paragraph 41 and the above subparagraphs of Plaintiffs Complaint. See e.g. Rubeck v. Milroth, 53 Pa. D. &C.4th 548 (Franklin Cty. 2001); Sola v. Chao, 49 Pa. D. &C.4th 444 (Montour Cty. 2000); Boyd v. Somerset Hosp., 24 Pa. D. &C.4th 3 564 (Somerset Cty. 1993); Flurer v. Pocono Med. Ctr., 15 Pa. D. &C.4th 645 (Monroe Cty. 1992); Starr v. Myers, 109 Dauphin 147 (1988); Fasula v. Hijazi, 44 Pa. D. &C.4th 553 (Lackawanna Cty. 1999); and Lichty v. Kucharczuk, 5 Pa. D. &C.4th 120 (Northampton Cty. 1989). 18. Paragraph 41 and the above subparagraphs of Plaintiff's Complaint do not give Defendant sufficient factual specificity to allow them to prepare an adequate defense. 19. The overly broad, boilerplate allegations of negligence identified above may allow the Plaintiff to later set forth new theories of negligence not originally pled, thereby prejudicing Moving Defendants from preparing a defense. See Connor v. Allegheny General Hosp., 461 A.2d 600 (Pa. 1983). 20. The allegations of negligence identified above are further prejudicial to Defendant insofar as these allegations may result in a waiver of various defenses and objections pursuant to Pa.R.C.P. No. 1032. WHEREFORE, Moving Defendants respectfully request that this Court enter its Order striking paragraph 41 and subparagraphs (a), (b), (c), (d), (e), (f), (g), (h), (i), 0), (k), (1), (m), (n), (o), (p), (q), (r), (s), (t), (u), (v), (w), (x), (y), (z) and (aa) of Paragraph 41 from Plaintiff s 4 Complaint in their entirety, or, in the alternative, direct Plaintiff to file a more specific complaint with respect to those allegations of negligence. Date: l / may/ 0 01 Respectfully submitted, THOMAS, THOMAS & By: Ee6 Black, Esquire ttomey I.D. No. 17884 Richard S. Wade, Esquire Attorney I.D. No. 209843 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 5 LLP CERTIFICATE OF SERVICE I, Richard S. Wade, Esq. Thomas, Thomas & Hafer, LLP, hereby certify that a true and correct copy of the foregoing document was sent to the following counsel of record by placing a copy of same by First Class in the United States mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Jeffrey T. McGuire, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 THOMAS, THOMAS & HAFER, LLP Date: November 24, 2009 Ric d S. Wade, Esquire FILED-t, t- >ur 2099 NIOV 25 Phi 2: 4 7 ry PRAECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. MICHELE C. NATALE, (Plaintiff) VS. (Defendant) BRICE D. ARNDT, DDS, 1 No. 07-6904 Civil State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Defendant's Preliminary Objections to Plaintiffs Complaint 2. Identify counsel who will argue case: (a) for plaintiff: Jeffrey T. McGuire, Esquire Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (b) for defendant: Richard Wade, Esquire Thomas, Thomas & Hafer, LLP 305 N. Front Street Harrisburg, PA 17108-0999 N ? 4 ? ate. o w -< 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: Dated: 3/1/2010 -`%, Richard S. Wade, Esq. Attorney for Defendant BLED-0i: ICE OF THE 20 10 APR 26 PPS 2: 54 WAL'.7 fly THOMAS, THOMAS & HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 eblack(a4tthlaw. com Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 honeill _,tthlaw.com 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 441-7051 Attorneys for Defendant Brice D. Arndt, DDS. MICHELE C. NATALE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. NO. 07-6904 BRICE D. ARNDT, DDS, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES NOTICE TO PLEAD You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, THOMAS, THOMAy?Bc HAFER, LLP Dated: / By: Aff-2 c Evan Black, Esquire Hugh P. O'Neill, III, Esquire THOMAS, THOMAS & HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 eblackythlaw.com Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 honeilla,,tthlaw. com 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 441-7051 Attorneys for Defendant Brice D. Arndt, DDS. MICHELE C. NATALE, Plaintiff V. BRICE D. ARNDT, DDS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6904 CIVIL ACTION -LAW JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES DEFENDANT BRICE D. ARNDT, DDS's ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant Brice D. Arndt, DDS, by and through his counsel, Thomas, Thomas & Hafer, LLP, and hereby files this Answer to Plaintiff's Complaint and responds as follows: 1. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion or belief as to the truth or falsity of the allegations contained in the corresponding paragraph of Plaintiff's Complaint. Accordingly, all said allegations are denied. All allegations are further denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 2. Admitted. 1-8. Denied as stated, rather, the medical and dental records of Plaintiff speak for themselves. To the extent the medical records conflict or are inconsistent with the corresponding allegations of Plaintiff's Complaint. All said allegations are specifically denied. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 9.-13. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion as to the truth or falsity of the allegations contained in the corresponding allegations of Plaintiff's Complaint. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). By way of further response, the medical records speak for themselves. All allegations are placed at issue and strict proof thereof is demanded at time of trial. 14. Denied. Rather, the medical and dental records of Plaintiff speak for themselves. To the extent the medical records conflict or are inconsistent with the corresponding allegations of Plaintiff's Complaint. All said allegations are specifically denied. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 15. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion as to the truth or falsity of the allegations contained in the corresponding allegations of Plaintiff's Complaint. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). By way of further response, the medical records speak for themselves. All allegations are placed at issue and strict proof thereof is demanded at time of trial. 16. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion as to the truth or falsity of the allegations contained in the corresponding allegations of Plaintiff's Complaint. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). By way of further response, the medical records speak for themselves. All allegations are placed at issue and strict proof thereof is demanded at time of trial. 17. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion as to the truth or falsity of the allegations contained in the corresponding allegations of Plaintiff's Complaint. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). By way of further response, the medical records speak for themselves. All allegations are placed at issue and strict proof thereof is demanded at time of trial. 18.-19. Denied. Rather, the medical and dental records of Plaintiff speak for themselves. To the extent the medical records conflict or are inconsistent with the corresponding allegations of Plaintiff's Complaint. All said allegations are specifically denied. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 20.-21. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion as to the truth or falsity of the allegations contained in the corresponding allegations of Plaintiff's Complaint. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). By way of further response, the medical records speak for themselves. All allegations are placed at issue and strict proof thereof is demanded at time of trial. 22.-23. Denied. Rather, the medical and dental records of Plaintiff speak for themselves. To the extent the medical records conflict or are inconsistent with the corresponding allegations of Plaintiff's Complaint. All said allegations are specifically denied. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. Moreover, all allegations that Defendant failed to perform appropriate follow-up exam, surgical treatment or extraction, and failed to inform Plaintiff of the pain or discomfort are further denied as conclusions of law. 24.-30. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion as to the truth or falsity of the allegations contained in the corresponding allegations of Plaintiff's Complaint. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). By way of further response, the medical records speak for themselves. All allegations are placed at issue and strict proof thereof is demanded at time of trial. 31.-32. Denied as stated, rather, the medical and dental records of Plaintiff speak for themselves. To the extent the medical records conflict or are inconsistent with the corresponding allegations of Plaintiff's Complaint. All said allegations are specifically denied. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at time of trial. 31-38. Denied. After reasonable investigation, Answering Defendant is without sufficient knowledge or information to form an opinion as to the truth or falsity of the allegations contained in the corresponding allegations of Plaintiff's Complaint. All allegations are generally denied pursuant to Pa. R.C.P. 1029(e). By way of further response, the medical records speak for themselves. All allegations are placed at issue and strict proof thereof is demanded at time of trial. COUNT I - NEGLIGENCE 39. Answering Defendant incorporates his responses to Paragraphs 1-38 of Plaintiff's Complaint as if set forth herein at length. 40. Denied as stated. Rather Defendant is a doctor of dental surgery and practices under the laws of the Commonwealth of Pennsylvania. All other allegations are denied as legal conclusions and denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. 41. Denied. Answering Defendants incorporates the Stipulation of Counsel striking subparagraphs (a), (b) and (aa) with prejudice. By way of further answer, the allegations contained in subparagraph (c) - (z) are specifically denied, denied as conclusions of law and pursuant to Pa. R.C.P. 1029(e). All allegations are generally denied pursuant to Pa. R.C.P. 1029 (e). Moreover, all allegations are placed at issue and strict proof thereof is demanded at the time of trial. 42. Denied. All allegations are specifically denied and generally denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. WHEREFORE, Answering Defendant demands judgment in his favor together with costs. COUNT II - LACK OF INFORMED CONSENT 43.46. Denied. Answering Defendant incorporates his responses to Paragraphs 1-42 of Plaintiff's Complaint as is set forth herein at length. All allegations of lack of improper informed consent are specifically denied, denied as conclusions of law and denied pursuant to Pa. R.C.P. 1029(e). All further allegations are also denied as conclusions of law and denied pursuant to Pa. R.C.P. 1029(e). All allegations are placed at issue and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant demands judgment in his favor together with costs. NEW MATTER 47. Answering Defendant's responses to Paragraphs 1-46 of Plaintiff's Complaint are incorporated as if set forth herein at length. 48. Plaintiff s Complaint fails to state a claim upon which relief can be granted. 49. Plaintiffs claims are barred by the applicable statute of limitations 42 Pa. C.S.A. §5524. 50. Answering Defendant was at no time relevant to the within cause of action negligent or careless. 51. Any acts or omissions of Answering Defendant alleged to constitute negligence and/or carelessness and/or malpractice were not the substantial causes or factors of the subject incident and/or did not result in any incident or injuries alleged by Plaintiff. 52. Plaintiff assumed the risk of medical treatment rendered. 53. Plaintiff s claims are barred, limited or reduced by the Pennsylvania Comparative Act, 42 Pa. C.S.A. §7102. 54. If the Plaintiff sustained injuries or damages or alleged, said allegations being specifically denied, said injuries were caused by Plaintiffs failure to exercise reasonable care under the circumstances and, therefore, Plaintiffs claims are barred or reduced by the Pennsylvania Comparative Negligence Act, 42 Pa. C.S.A. §7102. 55. If Plaintiff suffered injuries as alleged, such allegations being specifically denied, Plaintiff's injuries were caused by persons, entities, occurrences, instrumentalities or events unrelated to and not under the control of Answering Defendant. 56. Answering Defendant is entitled to and asserts all defenses on limitations and damages which are available to it under the Health Care Services Malpractice Act, 40 Pa. C.S.A. §1301.1.01. et seq. 57. Answering Defendant at all times material hereto, acted in a careful, reasonable, and prudent manner consistent with the required standard of care. 58. Answering Defendant is entitled to and incorporates herein by reference the defenses contained in the Federal Health Care Quality Improvement Act, P.L. 99-660. 59. The injuries and/or damages alleged to have been sustained by the Plaintiff were not proximately caused by Answering Defendant. 60. Any care and/or treatment which may have been provided by Answering Defendant was at all times, reasonable, proper, appropriate and conformed to the standard of care. 61. Pa.R.C.P. 238 for delay damages is inapplicable under the facts of the present case and is unconstitutional and in violation of the Constitution of the United States and the Constitution of the Commonwealth of Pennsylvania. 62. Plaintiff may have entered into a release, discharging Answering Defendant from any liability whatsoever in this matter. 63. Plaintiff's claims, the existence of which is specifically denied by Answering Defendant, may be reduced and/or limited by any collateral source of compensation and/or benefit in accordance with the Pennsylvania Supreme Court decision in Moorhead v. Crozer Chester Medical Center. 64. At all times relevant hereto, Answering Defendant acted within and followed the precepts of a school of thought followed by a considerable number of qualified and well respected specialists in the field and, accordingly, their professional conduct was fully commensurate with the applicable standard of care. Evidence at trial may establish two or more schools of thought applicable to the issues presented in this case. 65. In the event that it is determined that Answering Defendant was negligent with regard to any of the allegations contained in and with respect to the Plaintiff's Complaint, said allegations being specifically denied, discovery may establish that said negligence was superseded by the intervening negligent acts of other persons, parties and/or organizations other than Answering Defendant and over whom said Answering Defendant had no control, right of control, or responsibility and, therefore, Answering Defendant is not liable. 66. To the extent that the evidence may show that other persons, partnerships, corporations, or other legal entities caused or contributed to the injuries or the pre-existing condition of the Plaintiff, then the conduct of Answering Defendant was not the legal cause of such conditions or injuries. 67. Answering Defendant raises all affirmative defenses of the Medical Care Availability and Reduction of Error (M'Care) Act a/k/a Act 13 of 2002 as a limitibar to Plaintiff's claims. 68. Insofar as Answering Defendant or any person for whom she is or may be vicariously liable, elected a treatment modality which is recognized as proper, but may differ from another appropriate treatment modality, then Answering Defendant raises the " two schools of thought" defense. WHEREFORE, Answering Defendant denies any and all liability to any party whatsoever, demand that the case be dismissed with prejudice, and that judgment be entered in their favor. Respectfully submitted, THOMAS, THO Date: ! Z.3 /a By 'Evan Black, Esquire I.D. #17884 Hugh P. O'Neill, Esquire I.D. #69986 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7629 LLP VERIFICATION I, BRICE D. ARNDT, DDS, have read the foregoing Answer and New Matter to Plaintiffs Complaint which has been drafted by my counsel. 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. § 4904 relating to unsworn falsification to authorities, which provides that, if I knowingly make false averments, I may be subject to criminal penalties. Date: . 4,(-;-Q ) i BRICE D. ARND ",DS CERTIFICATE OF SERVICE I, Cindy J. Wilson, an employee for the law firm Thomas, Thomas & Hafer, LLP, hereby state that a true and correct copy of the attached document(s) was served upon all counsel of record by first class United States Mail, postage prepaid, addressed as follows, on the date set forth below: Jeffrey T. McGuire, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff THOMAS, THOMAS & HAFER, LLP Dated: C-- Cindy J. Wilson CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS G? ? _ l - o As a prerequisite to service of a subpoena for documents and thingsn, pursTtant ,- y-~n to Rule 4009.22 -: MCS on behalf of EVAN BLACK, 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: 03/25/2010 R1.86S 144-H MCS on beh of EVAN BLACK, Attorney for DEFENDANT DE11-1063035 14418 -LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CASE NO: 07-6904 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NICOLE M. YINGLING, DDS MEDICAL, BILLING, AND X-RAY(S) JOSEPH FOOTE, M.D. MEDICAL, BILLING, AND X-RAY(S) ENDODONTICS ASSOCIATES MEDICAL, BILLING, AND X-RAY(S) TO: JEFFREY T. MCGUIRE, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, 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: 03/03/2010 S on beha of BLACK, Attorney for D ENDANT CC: EVAN BLACK, ESQ. JEFFREY T. MCGUIRE, ESQ. CALDWELL & KEARNS 3631 N. FRONT STREET HARRISBURG, PA 17110333 TT&H 355-91452 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.86S 144-H DE02-0627838 14418-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NICOLE M YINGL.ING DDS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at _ The M CS Group. Inc.. 1601 Market Street, Suite 800, Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ES ADDRESS: 305 N. FRONT M TELEPHONE: f215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 2 5 2010' B THE COURT: Prot onotary/Clerk, Civil Division 11.?t3.?? ??d !D Deputy Date: Seal of the Court 14418-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NICOLE M. YINGLING, DDS MASON-DIXON ENDODONTICS 60 PARKWOOD DRIVE CHAMBERSBURG, PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : MICHELE A. NATALE 240 MINNICH ROAD, CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 R1.86S 144-H SU10-0828664 14418-LO1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 03/25/2010 R1.86S 144-H MCS on behalf of /S, EVAN BLACK, ESQ. Attorney for DEFENDANT DE11-1063039 14418 -L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOSEPH FOOTF M.D. C7[ li I?]" ll II_lf_'i II'-Lit lC)C1Cllli7f II11K]011111 011000J? (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: **** SEEATTACHFDRIDFR **** at The MCS Gro W. Inc 1601 Mark t r et 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: EVAN B A K ADDRESS: 305 N. FRONT STREET PO BOX 999 HARRISBURG PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: efendant 1 A-9-5 Seal of the Court BY THE COURT: y Pro onotary/Clerk, Civil Division Deputy 14418-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR JOSEPH FOOTE, M.D. 250 KING OF PRUSSIA ROAD 4TH FLOOR RADNOR, PA 19087 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : MICHELE A. NATALE 240 MINNICH ROAD, CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 R1.86S 144-H SU10-0828666 14418 -LO2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 03/25/2010 R1-86S 144-H MCS on beha f / EV BLA ESQ. Attorney for DEFENDANT DE11-1063040 14418 -L03 _ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. File No. 07-6904 BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records forENDODONTICS ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTAC F.D RIDER * * * * at The MC ro op Inc 1601 Market tree rite 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: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant B HE RT: Prothonotary/Cl rk, Civil Division MAR_ 2 ? 2?D1Q Deputy Date: Seal of-the-tdGrt . . . 14418-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ENDODONTICS ASSOCIATES 1199 COLONIAL ROAD HARRISBURG, PA 17112 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : MICHELE A. NATALE 240 MINNICH ROAD, CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 R1.86S 144-H SU10-0828668 14418-LO3 w ~,~ ~r ,. aolo ~uG Ia ~Pn~ t:Kl L~E~~-~ ~ ,;T,SS~ ~a~~Y 1 THOMAS, THOMAS 8 HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 eblack(a2tthlaw.com Hugh P. O'Neill, III, Esquire Attorney LD. 69986 honeill(a»tthlaw. com 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717)441-7051 Attorneys for Defendant Brice D. Arndt, DDS. MICHELE C. NATALE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff :PENNSYLVANIA V. BRICE D. ARNDT, DDS, NO. 07-6904 CIVIL ACTION -LAW Defendant :JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES DEFENDANT'S MOTION FOR STATUS CONFERENCE AND NOW COMES, Defendant, Brice D. Arndt, DDS, by and through his counsel, Thomas, Thomas & Hafer, LLP, and hereby files this Motion for Status Conference and avers as follows: 1. Plaintiff initiated this dental malpractice case against Defendant, associated with his failure to properly perform dental procedures and alleged retained dental instrument. 2. The parties are in the process of exchanging written discovery and are scheduling depositions. 3. Defendant would request a status conference for the purpose of scheduling the completion of factual discovery and depositions, exchange of expert reports and scheduling a date certain for this professional liability trial. 4. Defendants are not aware that any judge of the Cumberland County Court of Common Pleas has had prior involvement in this matter. WHEREFORE, Defendant respectfully requests that this Honorable Court grant Defendants Motion for Status Conference and enter an order in the form proposed. Respectfully submitted, THOMAS, TI~MAS~AFER, LLP Date: By /~ Ev lack, Esquire I.D. #17884 Hugh P. O'Neill, Esquire LD. #69986 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7629 840145.1 CERTIFICATE OF SERVICE I, Cindy J: Wilson, an employee for the law firm Thomas, Thomas & Hafer, LLP, hereby state that a true and correct copy of the attached document(s) was served upon all counsel of record by first class United States Mail, postage prepaid, addressed as follows, on the date set forth below: Jeffrey T. McGuire, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff THOMAS, THOMAS & HAFER, LLP Dated: ~ - S _ t O _ Cindy J Wilson s THOMAS, THOMAS & HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 eblack6aWhlaw.com Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 honeillaawhlaw. com 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717)441-7051 Attorneys for Defendant Brice D. Arndt, DDS. MICHELE C. NATALE, Plaintiff V. BRICE D. ARNDT, DDS, ; ii 2010 Al, AUG 112010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-6904 CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES ORDER AND NOW, this 13 day of a44W , 2010, upon consideration of the Motion for Status Conference of Defendant and any response thereto, it is hereby ordered and decreed that said motion is GRANTED and a scheduling conference is ordered for the , eday of lld??6 2010 at 5, 3Uo'clock before the Honorabl in Court Room 5 DISTRIBUTION LIST: Jeffrey T. McGuire, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, PA 17110 v Evan Black, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 *es ma: led 9113 f j0 RIVL a~,.,r a C THOMAS, THOMAS 8a HAFER, LLP Evan Black, Esquire Attorney I.D. 17884 eblac&na,tthlaw.com Hugh P. O'Neill, III, Esquire Attorney I.D. 69986 honeillntthlaw.com 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717)441-7051 Attorneys for Defendant Brice D. Arndt, DDS. MICHELE C. NATALE, Plaintiff V. BRICE D. ARNDT, DDS, i FILED-OFFICt: 0~' THE PROTHONOTARY 2010 OCT 25 PM I ~ 53 CUMBERLAt~O COUNTY PEf~'NSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6904 CIVIL ACTION -LAW Defendant :JURY TRIAL DEMANDED 12 JURORS AND ALTERNATES ORDER ~~ / AND NOW this 23 day of ®~ Cv ~~ , 2010, upon agreement of counsel, it is hereby ORDERED and DECREED that the Case Management Deadlines for the above matter are as follows: 1. Completion of factual discovery by March 31, 2011; 2. Submission of Plaintiff's expert reports by March 31, 201 l; and 3. Submission of Defense expert reports May 30, 2011. This court is awaze of Mr. Black's attachment for trial in the matter of Linke v. Sun Orthopaedics in Union County for the third quarter of 2011. In the event that this matter is continued or settled prior to July 15, 2011, this matter shall be tried during the civil trial term of September 19, 2011. Otherwise, this matter shall be tried no later than the civil trial term of December 5, 2011. ~~~ DISTRIBUTION LIST: Iugh P. O'Neill Thomas, Thomas & Hafer, LLP 305 North Front Street Harrisburg, PA 17101 honeill@tthlaw.com ~ey T. McGuire, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, PA 17110 852055.1 ~ ~~ toas~rv ~'r/l S '~ THOMAS, THOMAS & HAFERLLP Attorneys At Law Street Address: 305 North Front Street, Harrisburg, PA 17101 Mailing Address: P.O. Box 999, Harrisburg, PA 17108 Phone: 717.237.7100 Fax: 717.237.7105 Hugh P. O'Neill (717) 255-7629 honeill@tthlaw. com October 19, 2010 The Honorable Albert H. Masland Cumberland County Court of Common Pleas One Courthouse Square Carlisle, PA 17013 RE: Natale v. Arndt No. 07-6904 TT&H File No. 355-91452 Dear Judge Masland: Enclosed is a proposed Case Management Order for the above matter. You will recall that the Court had scheduled a case management conference on August 30, 2010. The conference did not take place per se, due to a conflict with a criminal bench trial. The parties were able to discuss the issues and have agreed upon a proposed case management schedule. This Order was previously provided to Plaintiff's Counsel, Attorney McGuire. We believe that he is in agreement with its terms. If the proposed Order is acceptable to the Court would you kindly enter the Order on the docket. Thank you for your kind attention. Respectfully yours, THOMAS, ugh P. HPO/cjw: cc: Evan Black, Esquire Jeffrey T. McGuire, Esquire Baltimore Bethlehem Harrisburg Philadelphia www.tthlaw.com HAFER, LLP Pittsburgh Wilkes-Barre CSRTIFICATB , ' ~~ PRSRBQUISITE TO SSRVICPC OF A SUBPOE ~~ ~ ~~ PURSUANT TO RUL19 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NRTALE TERM, CUMBERLAND -VS- BRICE D. ARNDT, DDS CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 R2.33 116-H tliPd'dA~tAS~i~~3~ ,~.± ~~noo ar~~~ ~~~a~~no c. ~ ~ ~ ~~ ~ ~ ~~o o ~ at ~~d 3~i~.~30 d~14.~ 1 ~0 MCS on behalf o/f /S/ wart each, ~~~. EVAN BLACK, ESQ. Attorney for DEFENDANT DSll-1189468 14418 -L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS - TT&H 355-91452 NOTICE OF INTENT TO SERVE A SIISPOENA TO PRODIICE DOCII![ENTS AND T$INt3S FOR DISCOVERY PIIRSIIANT TO RIILE 4009.21 [ Note: see enclosed list of locations ] TO: JEFFREY T. MCGUIRE, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, 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: 10/01/2010 CC: EVAN BLACK, ESQ. JEFFREY T. MCGUIRE, ESQ. CALDWELL & KEARNS 3631 N. FRONT STREET HARRISBURG, PA 17110333 COURT OF COMMON PLEAS TERM, CASE NO: 07-6904 MCS on behalf of EVAN BLACK, ESQ.. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R2.33 116-H D802-0715050 14418-CU1 .~ COMiyIONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PROSTHODONTICS INTERMRDIC (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 Gmi~, Inc., 1601 Market Stree~,~j iti a g00~ Philade~La~ 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 Ito seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE:1 15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant jai ~ Date: ` to/(o~i0 -~--~ BY THE COURT: ~7~uid~.~~1~ notarylCl Civil Division • ~ uty Seal of the Court 14418-05 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: ~PROS:THODONTICS INTERMEDIC ±467 PENNSYLVANIA AVENUE SUITE 210 ~':FQRT WASHINGTON. PA 19034 RE: 14418 'MiCHELE A. NATALE Prior approval is reQuired for fees is excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to .,..any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray faa3ns:aud tests. with subsequent reports, including any and all such .items as may be stored in a computer database or otherwise in electronic form, relating to. any. examination, consultation, diagnosis, care or treatment pertaining to: - ~~ Dates 8equested: up to and including the present. Subject s MICH8L8 A. ~TATALI3 .. 240 MI~ICB ROAD, CAAMBB&SBIIRQ, PA 17201 Social Security #s ]CZX-Z]C-1649 Date of Birth: 03-22-1965 2.33 116-H SII10-0867880 14418=LO5 CSRTIFICATS PRSRSQIIISITS TO SSRVICB OF A BIIBPOSNA PIIRSIIANT TO RIILB 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ van ~LaCI?, ~~g. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DS11-1189471 14418-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4019.22 TO; Custodian of Records for DR KiM & FRANKLIN O NT (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 TDER **** at The MCS Gr©un_ Inc.. 1601 Ma~*~t Street, ~i P 800, P it ~ ]~~ 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: EVAN BLACK. ESO. ADDRESS: SOS N. FRONTS F.FT _PO BOX 999 _HARItISBLIRG~ PA 17101 TELEPHONE:,I215~ 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ~ m BY THE COURT: Pro onotary/C i '1 Division De ty Seal of the Court 14418-06 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: ~`OR. .KIM & FRANKLIN CO ENT 757 NORLAND AVE 'SUITE 20 CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers. ;,satire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the ,consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray !films,and tests with subsequent reports, including any and all such items as mar be stored in a computer database or otherwise in electronic form, relating tQ.any examination, consultation, diagnosis, care or treatmeat pertaialt~g..to:..~. '; Dates Requested: up to and including the present. Subject MICHELE A. NATALE 240 MINNICB ROAD, C8AlaBSRSBURa, PA 17201 Social Security ~s ]CXE-XX-1649 Date of Birth: 03-22-1965 2.33 115-H SII10-oa67882 14418 -LOb CBRTI F ICATP! PRERB(~UISITB TO 88RVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behayl~f of /s/ van ~~ac~, ~~g. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H DE11-1189474 14418 -L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THi1~TGS FOR DISCOVERY PURSUANT TO RULE 4409.22 TO: Custodian of Records for THONLAS N. GOOD DDS (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 R_iDER * * * * . at The. MCS Groilp. Lnc.. 1b01 Market . treet~ ~i p 800, Phila~elph~ PA 19103 You tray 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 patty serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING. PERSON: NAME: ADDRESS: TELEPHONE:1~) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ACT 21.,x. Date: IOI~o 1/ 0 Seal of the Court BY THE. COURT: ~id~~tt ]oJ~ notary/ 1 ivil Division uty 14418-07 EXPLANATION OF REQUIRED RECORDS - " T0: CUSTODIAN OF RECORDS FOR: ._ ~ ..THOMAS N . GOOD, DDS ~" 19b2 SCOTLAND AVE CHAMBERSBURG, PA 17201 RE: 14418 MICHELE A. NATALE Friar approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limi'~ed.to 'any and all records, correspondence to and from the consulting and/or treating .physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray -films and tests with subsequent reports, including any and all such items as ttlay be stored in a computer database or otherwise in electronic form, .relating " to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. SLtb j ect z NICSRT+B A. ~U-TALS 240 MI~ICH ROAD, CHA1dH8R8BVR0, PA 17201 Social Security #z ZEE-EE-1649 Date of Birth: 03-22-1965 :2.33 116-H SII10-o8d~es4 14418-L07 CERTIFICATE PRBR$QUISITB TO SERVICE OF A SUBPO$NA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /s/ ~varc ~~ac~, ~~g. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H D811-1189476 14418-L08 COMMOi~1WEALTH OF PENNSYLVA~iIA COUNTY OF CUIyIBERLAND MICHELE A. NATALE vs. BRICE D. A.RNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4409.22 TO: Custodian of Records for STEVEN M. P RRF.TT.DDS (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: **** SF,E ATTACHED ER **** at The MGS Group. nc., 1601 Market Street, Suite 8QQ Philade phis PA 19103 You may deliver or snail .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. ff 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:. EVAN BLACK. ESOP ADDRESS: 305 N. FRONT STREET PO BOX 999 h[ARRiSBURG, PA 17101 TELEPHONE: ~~1246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ~:2~ ~0' Date: lo~f,,jo ~- Seat of the Court BY THE COURT: ~a,Yid~~u~f/ Prothonotary/ Civil Division i De uty 14418-08 EXPLANATION OF REQUIRED RECORDS TO. CUSTODIAN OF RECORDS FOR: STEVEN M. PARRETT,ODS •~::CUMERLAND VLY DENTAL CARE =99 ST. PAUL'S DRIVE CHAMBERSBURG, PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to ''any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical .reports, medication/prescription records, medical billing and payment records, x-ray .films and tests-with subsequent reports, including any and all such items as -'flay 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 s 1[IC8EL8 A. ~iATALB 240 MIN1iICH ROAD, CSAI~BRSBIIItQ, PA 17201 Social Security #s 33g-E7C-1649 Date of Births 03-22-1965 ~, :y ....) :2.33 llb-H• ~ SII10-0867886 14418 -L08 CBRTIFICATB PRBRBQUISITI! TO SERVICE OF A SUBPOIlNA PURSVANT TO RULI! 4009.22 IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ ~vart ~lac~, ~~~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DF11-1189480 14418-L09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROBERT L. MEYERS,DMD (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 M~rlcPt . treel, 4~ite 800, Philad Rh!~ PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:. NAME: ADDRESS: TELEPHONE:1~) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: /o ~6,~io Seal of the Court BY THE COURT: ~.v ~d~.~uet~ Prothonotary/ le Civil Division uty 1441:8-09 .EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: ~ROSERT L. MEYERS.OMD W000 & MYERS ORAL - . ;_,2Q7 SOUTH 32ND ST - :: CAMP' HILL, PA 17011 RE 14418 MICHELE A. NATALE Prior approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to .any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records,~x-ray films .and tests with subsequent reports, including any and all such items as ri~ty be stored in a computer database or otherwise in electronic form, relating ___ --'to.az~y'°examination, consultation, diagnosis, care or treatment pertaining to: bates Requested: up to sad including the present. . : _, ;... Subject s M3C8BLS A. RATALg . 240 MIB~ICB ROAD, CgAIdB$RSBDRQ, PA 17201 .~- Social Security #: EEZ-Z]C-1649 Date of Birth: 03-22-1965 ;. .; '.. . solo-0867888 1441$ -L09 C13RTIFICATS PRBRSQUZ8IT8 TO 88RVIC$ OF A SUSPOBNA PURSUANT TO RULE 4009.22 IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 R2.33 116-H MCS on behalf of / S / ~varc ~~ach, ~~q.. EVAN BLACK, ESQ. Attorney for DEFENDANT Dall-1189483 14418 -L1O COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ CHAMAE . B lit O PIT i. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** ATTA D R **** at The MCS Gmt~. na_ 1601 M~rlcet Street, Site 800, Phi ~ j~h~i , PA 1'9103 You >may .deliver or mail legible copies of the documents or produce. things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: _(215) 24b-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 'OCT 2 ~ ~0' Date: /o%~/o Seal of the Court 14418-10 BY THE COURT: EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: `CHAMBERSBURG HOSPITAL `MEDICAL RECORDS lit N. 7TH STREET ~" ~'CHAINBERSBURG, PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees is 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 a1l.patient.consent or refusal of treatment, procedures, test, and/or - medication, lab and diagnostic test results, including any and all "such_:t:~ms ~.~ y bj~ stored in a computer database or otherwise in electronic form, '. roT?ting~`to'any examination, consultation, diagnosis, care, treatment, _ ~di~iiission, ` discharge, or emergency care pertaining. to: _.. .. Dates Requested: up to and including the present. 'Subject s MIC88LB A. NATALE _ 240 MINNICB ROAD, CBANBSRSBDRa, PA 17201 Social Security #: 199-50-1649 ' Date of Birth: 03-22-1965 '.~>,;.- ..:.~:: 2.33 116-H solo-0867890 14418 -L10 CBRTIFICATL PREREQIIISITB TO SERVICE OF A SIIBPOLNA PIIRSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 10/21/2010 /S/ ~vait ~lac~, ~~g.. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DB11-1189485 14418-L11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 TO: Custodian of Records for _ CHAMBERSBURG HOSPI'I'Ai, (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 Groi~n_ Inc•~ 1601 Market Street ~i P 500 Phila~elnhia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to .seek,. in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: ~0~ TELEPHONE: ,.,{~ 151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 2-~; Z01p Date: /o/!i~/o Seal of the Court BY THE COURT: ~~~ ~~ l~ Pro onotary/ a Civil Division uty 14418-11 EXPLANATION OF REQUIRED RECORDS TQ: CUSTODIAN OF REGARDS FOR: CHAMBERSBURG ~iOSPITAL ' `BILLING DEPT. .. ~.:~760 E. WASHINGTON ST CHAMBERSBURG, PA 17201 ~2E :.14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or :delinquent ,.invoices, including any and all such items as may be stored in a computer '.database=or otherwise in electronic form, relating to any examination, ..:.consultation, diagnosis, care or treatment pertaining to: Dates 8eq~asted: up to and including the present. Sui~seCt s M~I~''8$L8 A. NATALB . . , 240 MI~iICB 80AD, CEhl~~sBURGti, PA 17201 8®aial Security #: 199-50-1649 ~~ "~'' _ ~ ~` Date of Births 03-22-1965 solo-oa67s9a 14418-L11 CERTIFICATE PRBRBQUISITL TO 88RVICP! OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /s/ van Mach, ~~~.. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H DE11-1189489 14418 -L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4A09.22 TO: Custodian of Records for _ CHAMBE SB 1R HO PiTA . (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 Gmitn_ lnc__ 1601 M rket freer, rit 800, Phila~e~ h~i PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You. have the right to,seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: 01246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ~2 Dater /O~/o~lD Seal of the Court $Y THE COURT: Pro onotary/ rk, Civil Division uty 14418-12 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: a~Nt~IBERS6URG HOSPITAL - ~ '~RADIaLOGY OEPT. 112 N. 7TH STREET `:`~ CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees fn excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, .'pertaining to: Dates Requested: up to and including the present. '. ? Sula j eCt MICBBLE A. ~ NATALB 240 MINNICB ROAD, CHAMBBRSBIIR@, PA 17201 ~ ' ti,., ., "Social .Security ~: 199-50-1649 Date of Births 03-22-1965. . -f .: .. 2.33 116=H sII10-0867894 14418-L12 CERTIFICATE PRBRLQUISIT$ TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND ` -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant. to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena''-which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189492 14418-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MOFFITT HE RT & VA .i TLAR GRO 1P (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 IDF,R **** at The MCS Groi=n: Inc•. 1601 Market Street,, ~' P g00~ philad nlia_ PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the. certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE:~~_5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 4~t 2~' Date: /o~(o% Seal of the Court BY TME COURT: `~~ ~ 1~ ~( Prothonotary/Clerk, Civil Division PAY 14418-13 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: '`MOFFITT HEART & VASCULAR GROUP 1000 N. FRONT STREET ~W~RMLEYSBURG, PA 17043 RE: 14418 MICHELE A. NATALE Prior approval is required for fees is eaoess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to. any and all records, correspondence to and from the consulting and/or treating physicians, files] memoranda, handwritten notes, history and physical reports, _,;~edcation/prescription records, medical billing and payment records, x-ray .films and tests with subsequent reports, including any and all such items .as may be stored in a computer database. or otherwise in electronic form, .relating tb=any e~camination, consultation, diagnosis, care or treatment pertaining to: - Dates Requested: ug to and including the present. subject s MICB$L8 A. ~iATALB 240 IdI1~NIC8 ROAD, CSANSI3RS8IIRa, PA 17201 social Security ~: EZE-EE-1649 Date of Births 03-22-1965 2.33 116-x svla-0867896 14418-L13 CBRTIFICATB PRBRSQIIISITB TO SBRVICL OF A SUBPOPCNA PURSIIANT TO RIILL 4009.22 IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be ,. served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /s/ ~varc Mach, ~a~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H D811-1189495 14418 -L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D, ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR. DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for IVLADEIRA CHIROPRACTIC (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 Gmun Inc 1601 Market Street. ui ~plijl~lph~i , PA 19103 You may deliver or mail legible copies of the documents, or. produce things requested by this subpoena, together with the certifiEate of cocnplaance, to the party making this request at the address listed above. You have the right to seek, in advance; .the reasonafiie cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: _~) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: IO:T 21'2010 Date: /D /0 Seal of the Court ~Y icy u~]P_~ 1 P onotary/Cl Civil Division uty 14418-14 EXPLANATION OF REQUIRED RECORDS TU:, I,;USTODIAN OF RECORDS FOR: MADEIRA CHIROPRACTIC 1124 KENNEBEC DRIVE CHAFIBERSBURG, PA 17201 RE: :14418 MICHELE A. NATALE Prior approval is required for .fees fa excess of $150.00 for hospitals, $100.00 for all other providers. ~nti:re medical, billing, and diagnostic file, including but not liirited to any and all records, correspondence to and from the consulting and/or treating •.physicians, files, memoranda, handwritten notes, history and physical reports, .medication/prescription records, medical billing and payment records, x-ray 'films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating ;to~a~y:examination, consultation, diagnosis, care or treatment pertaining to: Dates 8equesteds up to and including the present. Stsbjeot s l~ICSBLB A. NATALB 240 MIB1iIC8 ROAD, C8AM88RSBIIRa, PA 17201 .. Social Security ~s a]CE-Z7C-1649 Date of Births 03-22-1965 2.33 116-H BII10-0867898 14418 -L14 CECRTIFICATS PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 R2.33 116-H MCS on behalf of / s / van ~~ach, ~~q. EVAN BLACK, ESQ. Attorney for DEFENDANT DB11-1189498 14418 -L15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KENNRTH W. i TOR, 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 Ri ER **** at The MC ro~~_ Inc.. 1601 M rket treed SLitP 800, Philadelph~ PA 19103 You may. deliver or mail legible copies of the documents or produce things requested by this subpoena, together .with the cer-tificate of compliance; to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving-this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: ._305 TELEPHONE: 01.246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: L~IIC~ l~^~xx°~ Pro onotary/Cle Civil Division ~~ 2.~" uty Date: b~b~io Seal of the Court 14418-15 EXPLANATION OF REQUIRED RECORDS T0: CIiSTOD.IAN OF RECORDS FOR: KENNETH W. RICTOR, M.D. SCOTLAND FAMILY PRACTICE ~'~ 730 SCOTLAND RD h:SCOTLAND, PA 17254 RE 14418 MICHELE A. NATALE :.Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but-not limited to any and all records, correspondence to and from the consulting and/or treating .physicians, files, memoranda, handwritten notes, history and physical reports, _ medication/prescription records, medical billing and payment records, x-ray ~ins.and tests with subsequent reports, including any and all such items..as map be stored in a computer database or otherwise in electronic form, relating to any ,examination, consultation, diagnosis, care or treatment pertaining to: ~Da~e.s Requested: up to and including the present. Subject s atIG88LS A. NATALE 240 ~[IN~iICH ROAD, CSAILBSRSSUR(3, PA 17201 t_ • '-` - _.~ •• ~ ` Social Security $: EZX-E]C-1649 Date of Births 03-22-1965 j• .. ..=< : YT`s .. .., r :2.3~ 1~.6-H solo-0867900 14418 -~15 CBRTIFICATL i PRSRBQUIBITS TO BBRVICE OF A SUBPOgNA PURSUANT TO RIILE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, - CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ ~vart ~Cach, ~~~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H DE11-1189501 14418 -L16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DD5 File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 41109.22 TO: Custodian of Records for WAT - ART LEGAL DEPARTIVVIEENT (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: **** ATTACHED RID R **** at Zl-e MCS Groun Inc , 1601 Market Street Suite g00~p11i1~delphi~. PA 19143 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 Ti-IE FOLLOWING PERSON: NAME: RV AN BLACK. ESO ADDRESS: X05 N FRnNT STREET PO BOX449 NARRiS~1IRG,,PA 17101 TELEPHONE: ~?l~) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: !~ 2 Date: ~a /~ ~io Seal of the Court ~,yid 1~~e~( Prothonotary/ Civil Division ~Y 14418-16 EXPLANATION OF REQUIRED RECORDS :TO:: CUSTODIAN OF RECORDS FOR: WAL-MART LEGAL DEPARTMENT ... _,702 S.W. 8TH STREET ~ ~~~ .~~~w.:. BENTONVILLE, AR 727160215 RE: 14418 MICHELE A. NATALE Prior approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers. 5TORE# 5358, 100 SOUTH CONESTOGA DRIVE, SHIPPENSBURG, PA 17257. YNCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS PAID 'BY INSURANCE, COST NOT COVERED SY INSURANCE AND CURRENT BALANCE- Entire prescription and/or pharmaceutical file, including but not limited to az~y and all records, reports, correspondence, memoranda, complete history and... „t~5aymenti. records, including any and all such items as may be stored in a ,`.compt}~er database or otherwise in electronic form, pertaining to: Dates &equested: up to and including the present. ~ _ Subject : 1tIC8$LS A. NATAi,B ,; 240 MINNICB ROAD, CSAbtBBELSBIIRG, PA 17201 Social Security ~: 199-50-1649 Date of Birth: 03-22.1965 . .. i'p+. 2.33 116;~H 8II10-0867902 14418 -L16 CSRTIFICATS PRSRSQUISITS TO SSRVICS OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf//~/ of /S/ van ~lac~, ~~~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H DSil-1189503 14418 -L17 COMiVIONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. File No. 07-6904 BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOIL DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ RITE- CO PO ATION (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 iDFR **** at The MCS Croan~ Inc__ 1601 M~*1_cPt . tree, ~i P 800, Philade(R$, PA 19103 You-may deliver or mail leg~bie copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE:1~1246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant OCT 21 Date: /o /~~O Seal of the Court BY THE COURT: Prothonotary/C erlc, Civil Division uty 14418-17 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: .-.RITE-AID CORPORATION CUSTOMER SUPPORT P.O. BOX 31b5 ~~HARRISBURG. PA 17105 RE: .14418 MICHELE A. NATALE Prior approval is required for fees fa excess of $150.00 for hospitals, $100.00 for all other providers. STORE#.3609,. INCLUDING DETAILS COSTS OF PRESCRIBI3D I~AICATIONS OUTLINING CO$T PAID BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND - Vi'i',: BALANCE . - `Sritire prescription and/or pharmaceutical file, including but not limited~to al~p:aricl aYl records, reports, correspondence, memoranda, complete history and ~rrent..~records, including any and all such items as may be stored in a - bc°~npt~ter database .or otherwise in electronic form, pertaining to: -,~'.. . Dates Requested: up to aad including the present. ...^ ~. - ~ Subject s ~[ICHSLB A. NATALB . ~ ''` - 240 !LIl03ICH ROAD. CSAM88RSSIIRO, PA 17201 - Social Seourity #s EEE-]CX-1649 Date of Births 03-22-1965 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 10/21/2010 /S/ ~vart ~LaCi?, ~~l,~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H DS11-1189506 14418 -L18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBEiZLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COMPOUNDING RX APC?THE('A_RY, #4 (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 Groin. Inc._ 1601 Market treet, ~i P 800, Philadcln~ 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: EVAN BLACK. ESO. ADDRESS: _.305 N. FRONT STREET PO BOX 9.99 G, PA 17101 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: OCT 2~1i Date: to/!~/!o Seal of the Court Pro onotary/Cl Civil Division 14418-18 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: COMPOUNDiN6 RX APOTHECARY, #4 $1 LANCASTER AVE MALVERN, PA 19355 RE: 1441$ MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for .hospitals, $100.00 for all other providers. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS`D BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND CURRTsNT BALANCE. ''Entire prescription and/or pharmaceutical file, including but not limited to ~-any.:and all records, reports, correspondence, memoranda, complete history and ~a~nnent records, including any and all such items as may be stored in a -. ;:'~~Smputer database or otherwise in electronic form, pertaining to: _ . . ~ , :.... - ,pats R egaiesteds up to and including the present. Subjeot : 1[ICHBLg.A. BATALS 240 MINNICB ROAD, CSAN88RSBUEtA, PA 17201. Social Security 8: XEX-a][-1649 Date of Birth: 03-22-1965 .. :.;_ :2.33 116-x sQio-0867906 14418 -L18 CSRTIFICATS PRSRSQUISITS TO SSRVICS OF A SUBP08NA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ wart 0..5~ach, ~~c~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H DS11-1189509 14418 -L19 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOIL DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for G ANT FOOD ..(: i, D .PT (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 R **** at The MCS Troia. Inc.. 1601 Mar_k_et Stre-eta Seite 800 Philp hi , PA 19103 You may deliver or mail legible copies of the' documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek; in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: 305 TELEPHONE: 015,1246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ~'1' 2~.1~0` Date: IoIG ~~ BY THE COURT: ~id ~~ue~~ Pro notary/ rk, Civil Division Seal of the Court 14418-19 EXPLANATION OF REQUIRED RECORDS TU:: CUSTODIAN OF RECORDS FOR: GIANT FOODS LLC LEGAL DEPT ....1149 HARRISBURG PIKE CARLISLE. PA 17013 RE:.14418 MICHELE A. NATALE --Pror.'approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers. STORE#.443, 925 NORLAND AVENIIE, CHANIDERSBURG, PA 17201; INCLUDING ..DETAILS OF PRESCRIBED INDICATIONS OUTLINING COSTS PAID BY INSURANCE, "COSTS NOT COVERED BY INSURANCE AND CURRENT BALANCE. Entire. prescription and/or pharmaceutical file, including but not limited .to any.~nd all records, reports, correspondence, memoranda, ccxaplete history and • :~3~~a~ent rewords, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: ~, ~ Dates requested: up to and including the preseat. - Subject s 1[ICNBLS A. NATALE ' 240 ![INNICB ROAD, CH11l~8R$BUBa, PA 17201 ,;: Social Security #s E7CE-]Ca-1649 .' Date of Birth: 03-22-1965 I ~ • 33 116-x', ~ avlo-as679oe 14418 -L19 CBRTIFICATS PR$R$QUISITB TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of / S / ~vart ~~ach, ~~~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2 .33 116-H Dail-1189513 14418 -L2 0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THIl~iGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for. TARGET P ARMACY #2241 (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 inFR **** at The MCC ('mun. nc.. 1601 M~cket Street, ~i 800, Phila~e hi PA 19103 You may deliver or mail. lle copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail. to produce the documents or things required by this subpoena. within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE:,,,() 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: /o~G~a BY THE COURT: l~a.v id 1~. -"~i~~ Prothonotary rk, Civil Division aL Seal of the Court 14418-20 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORQS FOR: TARGET PHARMACY #2241 913 NORLAND AVE °~ ~C1#AMBERSBURG . PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers. .. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS LSAI'D BY INSURANCE, COST NOT COVERED BY INSURANCE AND CURRENIT BALANCE. ~~~ntire prescription and/or pharmaceutical file, including but not limited to 'any and all records, reports, correspondence, memoranda, complete history and ,~nt.,records, including any and all such items as may be stored in a. ~i3mputer database or otherwise in electronic form, pertaining to: 1 ~t '., QaCes 8equested: up to and iaolndiag the preseat. ., .:.`Sub feat s K1C8EI+8 A. NATALB .; .J .. •" 240 M7:~TICH EL011D, c81lNSSRSBU~L(~. PA 17201 'Social Security #s EEZ-EX-1649 ~ ... Date of Hirthz 03-22-1965 r ;. . 2.33 116-H CSRTIFICATB PREREQUISITE TO SSRVICB OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on beha//l~~f of /S/ ~vart a~~ac~, ~~~. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189516 14418-L21 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PARK AVENUE PHA ACY (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 **** 8t The MCS Cmu~r~, Inc., 1601 Market Street, ~i p 800, Phil d . per, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: ~.~~d,1~~1~ notary/ erk, Civil Division ~~ 2~1 uty Date: lD b !o Seal of the Court 14418-21 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: .:.PARK AVENUE PHARMACY X220 PARK AVENUE 'CHAMBERSBURG, PA 17201 . ' ' ' ~'RE: 14418 MICHELE A. NATALE Prior approval is required for fees in eaceae of $150.00 for hospitals, $100.00 for all other providers. INCLiJDING DETAILS COSTS OF PRESCRIBED INDICATIONS OUTLINING COSTS PAID BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND CURREN'P BALANCE. Entire: prescription and/or pharmaceutical file, including but not limited to any and all records, reports, correspondence, memoranda, complete history and -'`~~>~c~aent.records,. including any and all such items as may be stored 3n a ~~mputer-database ar otherwise in .electronic form, pertaining to: :; , ,. s Dates 8equested: up to and including the present. _~ ~ - $'ttt~ject .s MIC88tLE A. NATALB .. 240 MI~TNICH ROAD, CH]1MSSRSBIIRa, PA 17201 - `~ ~` `Social Security #: XZE-Za-1649 - . ~,.-• .:.;.:;;: Date of Births 03-22-1965 .. _..~ ~~.Y cd:t'i. 5 :. _. 2: 12.33 116-H SII10-0867912 14418 .=L21 CBRTIFICATB PRBRBQIIISITE TO SERVICE OF A StTBPOBNA PURBIIANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena., is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ van ~lac~, ~~~, . EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189518 14418 -L22 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NORLAND AVENt1F. PHARMACY (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 R .R **** at The MCS CrnLn_ nc_, 1601 M rket . treat, u P 800, Phila~iel~hi8, 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: F~V ADDRESS: 305 TELEPHONE: (Z 151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant tI~T 21 Date: /o b /O BY THE COURT: ~,~,d ~. ~3 !i onotary/Cle Civil Division De uty Seal of the Court 14418-22 EXPLANATIOi~T OF REQUIRED RECORDS ~' TO': ~ CUSTODIAN OF RECORDS FOR: NORLAND AVENUE PHARMACY .::.,757. NORLAND AVENUE SUITE 105 CHAMBERSBURG. PA 17201 ._. . {. ..._ R~: 14418 .~ MICHELE A. NATALE Prior approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING .DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS PAID BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND CURREN'P BALANCE. Entire prescription and/or pharmaceutical file, including but not limited to and all records, reports, correspondence, memoranda, complete history and paymenti records,. including any and all such items as may be stored in a computez database or otherwise in electronic form, pertaining to: . ,,r: ~~ ~ _' Dates Retested: up to aad iaaludiag the present. `~ - subject MIC8EL8 A. NATALR 240. ![I~TICS itOAD, C8111488RSBiTRfl, PA 17201 _ , . _ .. Social Security ~: ZZx-a7C-1649 _ _ _ Date of Birth: 03-22-1965 .. , . ..:,r?. ,2.'33 116-H? SII10-0867914 ].441.$-rL22 CERTIFICATE PRSRSQIIISITS TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: MICHELE A. NATALE COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- BRICE D. ARNDT, DDS CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 R2.33 116-H MCS on behalf of /s/ van ~Cac~, ~~~. EVAN BLACK, ESQ. Attorney for DEFENDANT DS11-1189521 14418 -L23 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS . File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THTI~IGS FOR DISCOVERY PURSUANT TO RULE 4049.22 TO: Custodian of Records for HER ERT L RAY, DMD (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 CmL~, Inc ~ 1601 Market Street. ite 80Q.gj~i~~ PA 1910' 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 fai! to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE:.,,(?) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant O~f_ 2 Date: ro Seal of the Court BY THE COURT: ~V tt`_I T.~.~t( Prothonotary) Civil Division 14418-23 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: :;-HERBERT L. RAY. DMD '°ASSUC. IN ENDOOONTICS,INC 510 PELLIS RD GREENSBURG, PA 15601 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ~INCLDDING RECORDS OF HEIDI A. RAY, D1~ID. Entire medical, billing, and diagnostic file, including but not limited to ,any. and all records, correspondence to and from the consulting and/or treating ysicia~s,: files, memoranda,.handwritten notes, history aad physical'-reports, m~diaaGioii/prescription records, medical billing and payment records, ~-ray ,fi.~~ns.and tests with subsequent reports, including any and all such items :as -'.`y-'be stored in a computer database or otherwise in electronic form, relating tiD•~ny.e~camination, consultation, diagnosis, care or treatment pertaining.-~to: Dates 8equesteds up to aad iaaludiag the pzeseat. Bub j eat : 1[ICSBLg A. 1gATALB 240 1~LIHNICH ROAD, CHA!®ERSBIIRO, PA 17201 Social 8eaurity #: EEE-EE-1649 Date of Birth: 03-22-1965 12.33 116-H SII10-0867916 14418-L23 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS G7 C? ? I-- As a prerequisite to service of a subpoena for documents and thing''MrsIgntrn to Rule 4009.22 2;v '"'- -urn C) -n 13 C-) I MCS on behalf of EVAN BLACK, ESQ." tV )>rn certifies that w (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 s' MCS on behalf of /S/ Evan ®2lac EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189469 14418 -L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS - TT&H 355-91452 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCDILZNTS ARD THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: JEFFREY T. MCGUIRE, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, 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: 10/01/2010 CC: EVAN BLACK, ESQ. JEFFREY T. MCGUIRE, ESQ. CALDWELL & KEARNS 3631 N. FRONT STREET HARRISBURG, PA 17110333 COURT OF COMMON PLEAS TERM, CASE NO: 07-6904 MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R2.33 116-H DE02-0715051 14418-C01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED PROSTHODONTICS INTERMEDIC DR. KIM & FRANKLIN CO ENT THOMAS N. GOOD, DDS STEVEN M. PARRETT,DDS ROBERT L. MEYERS,DMD CHAMBERSBURG HOSPITAL CHAMBERSBURG HOSPITAL CHAMBERSBURG HOSPITAL MOFFITT HEART & VASCULAR GROUP MADEIRA CHIROPRACTIC KENNETH W. RICTOR, M.D. WAL-MART LEGAL DEPARTMENT RITE-AID CORPORATION COMPOUNDING RX APOTHECARY, #4 GIANT FOODS LLC LEGAL DEPT TARGET PHARMACY #2241 PARK AVENUE PHARMACY NORLAND AVENUE PHARMACY HERBERT L. RAY, DMD MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS BILLING ONLY X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) PRESCRIPTION/PHARMACEUTICAL RECORDS PRESCRIPTION/PHARMACEUTICAL RECORDS PRESCRIPTION/PHARMACEUTICAL RECORDS PRESCRIPTION/PHARMACEUTICAL RECORDS PRESCRIPTION/PHARMACEUTICAL RECORDS PRESCRIPTION/PHARMACEUTICAL RECORDS PRESCRIPTION/PHARMACEUTICAL RECORDS MEDICAL, BILLING, AND X-RAY(S) R2.33 116-H DR02-0715051 14418-COI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 TO: Custodian of Records for PROSTHODONTICS INTERMFDIC (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 Can= Inc.. 1601 Market Street, rite 800, Phladelnhia, 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: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET PO BOX 999 HARRISBURG PA 17101 TELEPHONE: (15) 24640900 SUPREME COURT ID M ATTORNEY FOR. Defendant BY THE COURT: MT" T 1 Date: /o&Llo Pro notary/ 1 Civil Division iy-n Seal of the Court 1441"5 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: .PROSTHODONTICS INTERMEDIC 467 PENNSYLVANIA AVENUE SUITE 210 `.FORT WASHINGTON. PA 19034 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as maybe 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 : NICB'SL8 A. NATALS 240 KIIMICH ROAD, CRAMBERSDIURG, PA 17201 social security #: XXX-XX-1649 Date of Birth: 03-22-1965 2.33 116-H SU10-0867880 14418=L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ evan gaach, da. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189472 14418-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 40".22 TO: Custodian of Records forDR KIM & FRANKLIN CO ENT (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 0map- Inc. 1601 arket Street, i.PholadelphilL PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. .if you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: ,.(21.5) 246-0900 SUPREME COURT :ID ATTORNEY FOR: Defendant W-WrAw .. fio.dw Date: Seal of the Court BY THE COURT: Avid --b.- Pro otarVIC Division Am AA- ty 14418-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. KIM & FRANKLIN CO ENT `757 NORLAND AVE SUITE 20 CHAMBERSBURG, PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ;:Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the,consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray "ills.and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to. any, examination, consultation, diagnosis, care or treatment pertaining. _.to:..,,. Dates Requested: up to and including the present. Subject : MICHELE A. X&TALE 240 MXMXCH ROAD, CR MBERSBURG, PA 17201 Social Security S: EZZ-EE-1649 Date of Birth: 03-22-1965 2.33 116-H SU10-0867882 14418 -LO6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ evan 121ach. 0e6a. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189475 14418-L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THOMAS N GOOD. DDS (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 Ctot{js, Inc.- 1.601 Market Street Suite 800, Phil n is PA 19103 You may deliver or mail legible. copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE:. (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR. Defendant XT 21-'M Date: Iol&-1 o Seal of the Court BY THE. COURT: r?vid?. t??J notary/ 1 ivil Division uty 14418-07 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: .:THOMAS N. GOOD. DDS 1962 SCOTLAND AVE CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limCed to. any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray -films and tests with subsequent reports, including any and all such items as y be stored in a computer database or otherwise in electronic form, relating f-01, any examination, consultation, diagnosis, care or treatment pertaining to- Dates, Requested: up to and including the present. Subject : MICHELE A. NATALS 240 MINNICH ROAD, CHAKBBRSB=G, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 2.33 116-H BUIO-0867884 14418 -L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ evan Mach, e4a. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189478 14418 -L08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 VS. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR TIHNGS FOR DISCOVERY PURSUANT TO RULE 4609.22 TO: Custodian of Records for STEVEN M. P RRE T.DDS (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 Gr=- Inc._ 1601 Market Sl . Suite 800, P it dejpljig, PA 19103 You may deliver or mail leggible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: . ADDRESS: TELEPHONE: (2,15) 24641900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: lode I/O BY THE COURT: id Prothonotary/ Civil Division i uty Seal of the Court 14418-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STEVEN M. PARRETT,DDS .-.CUMERLAND VLY DENTAL CARE =99 ST. PAUL'S DRIVE CHAMBERSBURG, PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for ,hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any-and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and.physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as .-may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates A•equesteds up to and including the present. Subject : KICBELE A. NATALE 240 l INNICH ROAD, CHAKSERSBURG, PA 17201 Social Security #s XXX-XX-1649 Date of Births 03-22-1965 2.33 116-H OU10-0867886 14418 -LO8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of / S / evan Aglach, ed4. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189481 14418 -L09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4049.22 TO: Custodian of Records for ROBERT L. M EYERS,DMD (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 Ca=- Inc.. 1601 Market Street, Suite 800, P iladelahia_ PA 19103 You may deliver or mail l4ble copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (215) 246-0900 SUPREME COURT ID M ATTORNEY FOR: Defendant OCt 2-`t Date: Ib &ho Seal of the Court BY THE COURT: otary! Civil Division 14418-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROBERT L. MEYERS,DMD WOOD & MYERS ORAL :.207 SOUTH 32ND ST CAMP HILL, PA 17011 RE-:: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Satire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating 'physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as ,"y be stored in a computer database or otherwise in electronic form, relating ;`to.any examination, consultation, diagnosis, care or treatment pertaining_td: Dates Requested: up to and including the present. Subject : MICMU A. NATALL+ 240 KINVICH -ROAD, CRAMBBBSBURGI, PA 17201 social Security S: xxx-xx-1649 Date of Birth: 03-22-1965 2.33 116-H sU10-0867889 14418 -LO9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS - CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of ?. /S/ van Aglach, EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189484 14418 -L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07,6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHAMBERSBURG 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 Gr=- Im., 1601 Market Street, Suite 800, Pbiladelphi& PA 19103 You -may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: 215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant rWT 2.t 1 Date: Ib/??/e --TT Seal of the Court 14418-10 BY THE COURT: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: .`CM4BERSBURG HOSPITAL MEDICAL RECORDS 112 N. 7TH STREET CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE 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-item icy :,stored in a computer database or otherwise in electronic form, tai t*fig``to any. examination, consultation, diagnosis, care, treatment; Os`ion, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. `SubjOct : KICHELE A. NATALE 240 MINNICH ROAD, CHAKBERSBURG, PA 17201 Social Security #: 199-50-1649 Date of Birth: 03-22-1965 s:. 2.33 116-H BUIO-0867690 14418 -L10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behallf of /S/ evan 1200ach, e44v._ EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189487 14418 -Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DLSCOVERY PURSUANT TO RULE 480312 TO: Custodian of Records for CHAMBERSBURG 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 GtoL1F 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: ADDRESS: TELEPHONE: (215) 245-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 2,11?p Date: 10&fio Seal of the Court BY THE COURT: ZPW otaryi Civil Division 14418-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG HOSPITAL BILLING DEPT. 760 E. WASHINGTON ST CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, 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.Reaested: up to and including the present. Subject : !MI LE A. NATAL8 240 MUNICH ROAD, CMUIR SBURG, PA 17201 .Social security #: 199-50-1649 ' Date of Birth: 03-22-1965 2.33 116-H sII10-0867892 14418 -Ll l CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -vs- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 Z- MCS on behalff of /S/ evan Mach, 64. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189490 14418-L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE vs. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO MMUCE DOCUMENTS OR TMGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for A SB 1RG 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 CTM- Inc., 1601 Market Street Suite 500, Philade ph,?i , 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 patty serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE:.() 2464RW SUPREME COURT ID #: ATTORNEY FOR: Defendant MY:* ft W. Date: Seal of the Court BY THE COURT: P / Civil Division ty 1441&12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: 0i ERSBURG HOSPITAL ?RAOIOLOGY DEPT. 112 N. 7TH STREET CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $500.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may .,be stared in a computer database or otherwise in electronic form, pertaining.to: Dates Requesteds up to and including the present. Subject s MI1CEL8 A. • NATALB 240 MINNICK ROAD, C8AMBMSBDRO, PA 17201 "Social Security #s 199-50-1649 Date of Births 03-22-1965. 2.33 116=H SU10-0867894 14418-L12 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ evan 12lDach, -44. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189493 14418-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MOFFITT 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 M TMUp, Inc.. 1601 ar cet Sheet, Suite 900, Philadelphhj & PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the. certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (215) 2464MM SUPREME COURT ID #: ATTORNEY FOR: Defendant Mr Date: Seal of the Court BY THE COURT: ProthonotarylClerk, Civil Division ruty 14418-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: `MUFFITT HEART & VASCULAR GROUP 1000 N. FRONT STREET - WORMLEYSBURG. PA 17043 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to Any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, ;;tnsdication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form,.relating £b=ahy examination, consultation, diagnosis, care or treatment pertaining to: Dares Requested: up to and including the present. Subject : KICRELS A. NATAL8 240 KIMIC8 aw?D, CHAMBROBUR+O, PA 17201 social Security 9: XXX-XX-1649 Date of Birth: 03-22-1965 2.33 116-H sV10-0867896 14418 -L13 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 v MCS on behalf of J-9A /S/ evan 12D ach, 64. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189496 14418 -L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR 11MGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MADEIRA CHIROPRACTIC (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 Grnilp, lw-. 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: ADDRESS: TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR. Defendant OCT 2:r 2010 Date: i &&0 Seal of the Court BY THE COURT: I ?Yic? ?_ .btL??? otaryiCl Civil Division +Uty ? Z-? - - I j% o?-n 14418-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MADEIRA CHIROPRACTIC 1124 KENNEBEC DRIVE CHAMBERSBURG, PA 17201 RE:.14418 MICHELE A. NATALE Prior approval is required for.fees in excess of $150.00 for hospitals, $100.00 for all other providers. :retire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating ::physicians, files, memoranda, handwritten notes, history and physical reports,: .medication/prescription records, medical billing and payment records, x-ray :films and tests with subsequent reports, including any and all such items as may he,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 : KXCMMX A. NATALS 240 MINNICH ROAD, CHAMSSRSHIIRG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 :2.33 116-H suio - 0867898 14 418 - L 14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ Cvan gD lach, 3q. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189499 14418-L15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF .CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR TIMES . FOR DISCOVERY PURSUANT TO RULE x.22 TO: Custodian of Records for KENNETH W. RICTOR. 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 ER * * * * at The MCS un Inc 1601 Market Street Suite 800. lphiL PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (215) 2464MM SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: 1?ow?d ?'?uea i notary/C Civil Division Date: he o Seal of the Court 14418-15 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: KENNETH W. RICTOR, M.D. °SCO?D FAMILY PRACTICE :730 SCOTLAND RD ,-;SCOTLAND. PA 17254 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray 'liaa.and tests with subsequent reports, including any and all such items-as may be stored in a computer database or otherwise in electronic form, relating to. any-examination, consultation, diagnosis, care or treatment pertaining to: Dat*a requested: up to and including the present.. subject : NICUMA A. NATALE C, 240 KIMICR ROAD, CRUIBMWBORG, PA 17201 8acial security #: xxx-xx-1649 Date of Birth: 03-22-1965 ;2; -H sUIO-0967900 14418-x,15 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of L-??a4 / S / evan Mach, 6q. - -- EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189502 14418-L16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 074904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WAL-MART LEGAL DEPARTMENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER * * * * at The MCS Graff 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: ADDRESS: TELEPHONE: (215 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant '2 M Date: ro4sho Seal of the Court BY THE COURT: 1-111A,v id t;-?ue l Prothonotary! Civil Division law uty 14418-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WAL-MART LEGAL DEPARTMENT 702 S.W. 8TH STREET BENTONVILLE, AR 727160215 RE: 14418 MICHELE A. NATALE Pirior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. STORE# 5358, 100 SOUTH CONESTOGA DRIVE, SHIPPENSBURG, PA 17257. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS PAID BY INSURANCE, COST NOT COVERED BY INSURANCE AND CURRENT BALANCE. Entire prescription and/or pharmaceutical file, including but not limited to any and all records, reports, correspondence, memoranda, complete history and pa.awnt. records, including any and, all such items as may be stored in a ct?tapu?er database or otherwise in electronic form, pertaining to: Dates Regnasted: up to and including the present. Subject s KICEMS A. NATALB _ 240 MINNXCS ROAD, CRANSERSBURG, PA 17101 Social Security #s 199-50-1649 Date of Birth: 03-22-1965 2.33 116;;H CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ Evan O2faci, 6q. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189505 14418 -L17 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS Fite No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DLSCOVERY PURSUANT TO RULE 4489.22 TO: Custodian of Records for RITE-AID CORPORATION (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 RIIDER * * * * at The MCS Graff, Inc.- 1601 Market Street, Suite 800, Ph' a&lnbi& 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: EVAN BLACK. ESO. ADDRESS: 305 N. FRONT STREET PO BOX 999 HARRISBURG, PA 17101 TELEPHONE: (215) 24640900 SUPREME COURT ID #: ATTORNEY FOR. Defendant BY THE COURT: OCT 21 " Daze: /0 /1& Seal of the Court T--Av ,ct ? tj Prothonotary/C erk, Civil Division De&ty 14418-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: .:'RITE-AID CORPORATION CUSTOMER SUPPORT P.O. BOX 3165 HARRISBURG, PA 17105 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. .STORE# 3609,. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COST PAID BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND r-URRRNT.BALANCE. Entire prescription and/or pharmaceutical file, including but not limited to aidd all records, reports, correspondence, memoranda, complete history and "Went records, including any and all such items as may be stored in a _MpUter database-or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject JaCMME A. ULTALE 240 KINNICB ROAD, CRiIiL MSBURG, Pik 17201 Social Security #: ZZE-XX-1649 Date of Birth: 03-22-1965 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 R2.33 116-H MCS on behalf of ?7 /S/ evan g/ lach, e3AL._ EVAN BLACK, ESQ. Attorney for DEFENDANT DE11-1189508 14418 - L18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COMPOUNDING RX APOTHECARY' #4 (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=n Loc.. 1601 Market Sheet. Suite Boo. Philade ia. PA 19103 You may deliver or mail legible copies. of the, documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. H 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: EVAN BLACK ESQ. ADDRESS: 305 N. STREET PO BOX 999 HARRISBURG, PA 17101 TELEPHONE:. (21,5) 246-09©0 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Off 21 Date: /O 4 !D Seat of the Court ?Y?.y id 1??ae( j 7 notary/C Civil Division 14418-18 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMPOUNDING RX APOTHECARY. #4 81 LANCASTER AVE MALVERN. PA 19355 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS' A?T-b BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND CURRENT BALANCE. Entire prescription and/or pharmaceutical file, including but not limited to any.and•all records, reports, correspondence, memoranda, complete history and yment records, including any and all such items as may be stored in a !fp titer database or otherwise in electronic form, pertaining to: ' pats Requested: up to and including the present. subject s MICHSLB A. ULTALB 240 MINNICH ROAD, CH71M88RSBURG, PA 17201 Social Security #: EZE-XX-1649 Date of Birth: 03-22-1965 2.33 116-H BUIO-0867906 14418 -L18 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS - CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ Cvan 12L4, ah, edq. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189511 14418-L19 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GIANT FOODS LLC LEGAL DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MQ Croup Inc' 1601 Market Street, Suite SO- deli, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (215)246-WO SUPREME COURT ID #: ATTORNEY FOR: Defendant t21 Date. c G W Seal of the Court BY THE COURT: 7 notary! Civi1 Division J411 ach" utY 14418-19 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GIANT FOODS LLC LEGAL DEPT 1149 HARRISBURG PIKE CARLISLE. PA 17013 RE:. 14418 MICHELE A. NATALE Prior-approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. STORE# 443, 925 NORLAND AVENUE, CHAMBERSBURG, PA 17201; INCLUDING DETAILS OF PRESCRIBED MEDICATIONS OUTLINING COSTS PAID BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND CURRENT BALANCE. Entire prescription and/or pharmaceutical file, including but not limited.to any.and all records, reports, correspondence, memoranda, complete history and ?pijzient.records, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requesteds up to and including the present. Subject : MIC&SLE A. YATAL$ - 240 KINNICB ROAD, csaxBSRSSURG, PA 17201 social security #: X=-EX-1649 Date of Birth: 03-22-1965 ;2.33 116-H: SUIO-0867908 14418-L19 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ evan &4 EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1109514 14418-L20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for TARGET PHARMACY #2241 (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 MCS Cm Inc.- 1601 Market Street Suite 800, Philadelpbja, PA 19103 You may deliver or mail. legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to. the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant TA Date: /o /i ro Seal of the Court BY THE COURT: L Ick 1( Prothonotary Civil Division A ON29 uty - 14418-20 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TARGET PHARMACY #2241 913 NORLAND AVE CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS` PAID BY INSURANCE, COST NOT COVERED BY INSURANCE AND CURRENT BALANCE. Entire prescription and/or pharmaceutical file, including but not limited to any and all records, reports, correspondence, memoranda, complete history and p$ nt..•records, including any and all such items as may be stored in a. .00mputer database or otherwise in electronic form, pertaining to: AaCes Requested: up to and including the present. Subject : KICBSLE A. ULTALE 240 llIMICB ROAD, CRAMWERSBURG, PA 17201 Social Security #: EE3-EE-1649 Date of Birth: 03-22-1965 2.33 116-H CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of CG c.? /s/ Evart glach, CJq. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189517 14418-L21 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. _ 07-6904 VS. BRICE D. ARNDT, DDS SUBPOENA M PRODUCE DOCUMENTS OR TANGS FOR DISCOVERY PURSUANT TO RULE 4049,22 TO: Custodian of Records for PARK AVENUE PHARMACY (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 SM Suite 800, P it delphi& PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (21) 24640900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: J Yi V kk rutynot)oy/ erk, Civil Division ?, 1 • Date: /0/&//o Seal of the Court 14418-21 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PARK AVENUE PHARMACY =220 PARK AVENUE 'CHAMBERSBURG, PA 17201 '.'RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS PAID BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND CURRENT BALANCE. Entire: prescription and/or pharmaceutical file, including but not limited to any and all records, reports, correspondence, memoranda, complete history and 't records, including any and all such items as may be stored in a di-database-or otherwise in electronic form, pertaining to: Dates;Requested: up to and including the present. sjnbject.s MICHELE A. NATALB 240 MINNICK ROAD, CRAMBERSBURa, PA 17201 `Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 V 12.33 116-H 8910-0867912 14418--x,21 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -v5- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of /S/ evan Mach, 64. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189520 14418-L22 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 TO: Custodian of Records for NORLAND AVENUE PHARMACY (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 Gm=. lnc., 1601 acket Street, Suite 300, P iladelphi, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: 01246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant OCT 21 r a Aj Date: D Seal of the Court BY THE COURT: Z?Avid // onotary,tCl Civil Division 0 uty 14418-22 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/2010 MCS on behalf of (;: /S/ evan 12L4, ah, 64. EVAN BLACK, ESQ. Attorney for DEFENDANT R2.33 116-H DE11-1189523 14418-L23 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4089.22 TO: Custodian of Records for HERBERT L. RAYS DMD (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 Cm= Inc._ 1601 Market Street, S i e 800, PhiladoWbia PA 19103 You-may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: (215) 24640900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Off 2 L Date: Seal of the Court BY THE COURT: Prothonotary! Civil Division ty 14418-23 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NORLAND AVENUE PHARMACY 75T NORLAND AVENUE SUITE 105 CHAMBERSBURG. PA 17201 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING DETAILS COSTS OF PRESCRIBED MEDICATIONS OUTLINING COSTS PAID BY INSURANCE, COSTS NOT COVERED BY INSURANCE AND CURRENT BALANCE. Entire prescription and/or pharmaceutical file, including but not limited to and,_all records, reports, correspondence, memoranda, complete history and payment records, 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 : KIC RA A. Nuzus 240 KINNICS ROAD, CHANBW SSUM, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 12.33 116-H SII10-0867914 14418-L22 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERBERT L. RAY. DMD ASSOC. IN ENDODONTICS,INC 510 PELLIS RD GREENSBURG, PA 15601 RE: 14418 MICHELE A. NATALE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING RECORDS OF HBIDI A. RAY, DMD. Entire medical, billing, and diagnostic file, including but not limited to aoy.and.all records, correspondence to and from the consulting and/or treating p ys cia s, files, memoranda,.handwritten notes, history and physical'-reports, medioation/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items:as uy=be stored in a computer database or otherwise in electronic form, relating to airy examination, consultation, diagnosis, care or treatment pertaining--to: Dates Requested: up to and including the present. Subject KICMMS A. X&TALB 240 ![I!!lTICB ROAD, CRAMBBABBURG, PA 17201 Social Security #z MM-XX-1649 Date of Births 03-22-1965 X2.33 116-H SUIO-0667916 14418-L23 on- % CERTIFICATE TiLIE- L)-0F 1 ICF PREREQUISITE TO SERVICE OF A SUBPO$fA- ?. E C OT ?I(INQTA 't' PURSUANT TO RULE 4009.22 2011 APff CUMBERLAND rJ44 PENNSYLVANIA IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS-- BRICE D. ARNDT, DDS CASE NO: 07-6904 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on. behalf of EVAN BLACK, 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:_03/2J_/207.1 MCS on Y lf o f // /S/ evan B//??ach SS , Jq. EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L30 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CASE NO: 07-6904 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PROSTHODONTICS INTERMEDIC DR.BARRY SHERMAN,DDS DR. THERESA WILSON DR.GERRY B PEREZ,DMD CUMBERLAND VALLEY FAMILY PHYS. DR.RICHARD J.FRANK,DDS DENTAL RECORDS DENTAL RECORDS MEDICAL, BILLING, AND X-RAY(S) DENTAL RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) TO: JEFFREY T. MCGUIRE, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, 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: 02/28/2011 MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT CC: EVAN BLACK, ESQ. JEFFREY T. MCGUIRE, ESQ. CALDWELL & KEARNS 3631 N. FRONT STREET HARRISBURG, PA 17110333 TT&H 355-91452 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 14418-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for_ DR I AR I F ANK,DDS (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 IDFR **** at The M Cm=, Inc 1601 Market Street, Sid 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: EVAN BLACK ES ADDRESS: 305 N_ FRONT ITT, TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date:" Seal of the Court O T- tary/Cle 'Civil Division qProthon Deputy 14418-30 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR.RICHARD J.FRANK,DDS 10000 MOLLY PITCHER HWY SHIPPENSBURG, PA 17257 RE: MCS # 14418-00 MICHELE A. NATALE 240 MINNICH ROAD CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 Please provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EMG's, MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Including but not limited to treatment on or about 9/12/1998 Priorapproval is required for fees in excess of $150.00 for hosp , $1,00.00 for all other providers. MCS # 14418-C01-00 SU02 CERTIFICATE a , PREREQUISITE TO SERVICE OF A SUBPOENA'S 't PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pur@var#ta--, to Rule 4009.22 ;;M may' MCS on behalf of EVAN BLACK, ESQ. certifies that _ N (1) A notice of intent to serve the subpoena with a copy of the `s`&bp'66na 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: 03/07/2011 MCS on behalf of /S/ evan 12Lac 6 EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L25 DE11 I I , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CASE NO: 07-6904 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PROSTHODONTICS INTERMEDIC DR.BARRY SHERMAN,DDS DR. THERESA WILSON DR.GERRY B PEREZ,DMD CUMBERLAND VALLEY FAMILY PHYS. DENTAL RECORDS DENTAL RECORDS MEDICAL, BILLING, AND X-RAY(S) DENTAL RECORDS MEDICAL, BILLING, AND X-RAY(S) TO: JEFFREY T. MCGUIRE, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, 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: 02/15/2011 CC: EVAN BLACK, ESQ. JEFFREY T. MCGUIRE, ESQ. CALDWELL & KEARNS 3631 N. FRONT STREET HARRISBURG, PA 17110333 - TT&H 355-91452 MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 14418-CO1 DE02 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PROSTHODONTICS INTERMEDIC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Groun, Inc., 1601 Market Street. Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it.. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: , _ NAME: EVAN BLACK. ESQ. ADDRESS: 305 N. FRONT STREET PO BOX 999 HARRISBURG, PA 17101 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant THE Deputy Date: Seal of the Court Civil Division 14418-25 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PROSTHODONTICS INTERMEDIC 467 PENNSYLVANIA AVENUE SUITE 210 FORT WASHINGTON, PA 19034 RE: MCS # 14418-L25 MICHELE A. NATALE 240 MINNICH ROAD CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 Please provide entire dental, billing, and diagnostic file from 09-01-2010 to the present, including but not limited to any and all records, correspondence to and from consulting and treating physicians. All files, memoranda, records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Any & all dental records, billing statements & copies of films. Prior aalproval is required for fees in excess of $150.00 for hospi , $100.00 for all other providers. MCS # 14418-L25 SU10 I CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 03/07/2011 MCS on behalf of /S/ Lan O21ach 6 . EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L26 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE VS. BRICE D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR BARRY SHERMAN-DDS (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 Gr=. Inc- 1,601 Market Street, Suite 800, P iladelpllia 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: EVAN BLACK. ES ADDRESS: 305 N. FRONT STF TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE OUR r Prothonotary/Clerk, Civil Division Deputy 14418-26 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR.BARRY SHERMAN,DDS SHERMAN DENTAL ASSOC 4700 UNION DEPOSIT HARRISBURG, PA 17111 RE: MCS # 14418-L26 MICHELE A. NATALE 240 MINNICH ROAD CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 Please provide entire dental, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from consulting and treating physicians. All files, memoranda, records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Any & all dental records, billing statments & copies of films. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 14418-L26 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 03/07/2011 MCS on behalf of /S/ evan O. LA, e4L1t"X EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L27 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 VS. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. THERESA WILSON (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: **** **** at The MCS Groun Inc 1601 Market Street &U 800- PhHadelnhia. 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: EVAN BLACK. E ADDRESS: 305 N. FRONT SZ TELEPHONE: (215) 246- 90U SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR'0.9 2011: Date: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 0000000000 000 Puty 14418-27 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. THERESA WILSON 2000 SCOTLAND AVENUE CHAMBERSBURG, PA 17201 RE: MCS # 14418-L27 MICHELE A. NATALE 240 MINNICH ROAD CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 Please provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EMG's MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitaU, $100.00 for all other providers. MCS # 14418-L27 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 03/07/2011 MCS on behalf D o//f /S/ evan Bach, e3 ?,E ?. EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L28 DE11 • COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 VS. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400912 TO: Custodian of Records for DR GERRY B PEREZ.DMD (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: ****SEEATTACHED **** at The MCS CYrouo x..1501 Market Street, Suite 800, Philadelphi?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: EVAN BLACK. E ADDRESS: 305 N. FRONT ST TELEPHONE: (715.) 246-MU SUPREME COURT ID #: ATTORNEY FOR: Defendant ,M 0.9 2011.1 1./f Date: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy 14418-28 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR.GERRY B PEREZ,DMD 43 CONNELLSVILLE STREET DUNBAR, PA 15431 RE: MCS # 14418-L28 MICHELE A. NATALE 240 MINNICH ROAD CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 Please provide entire dental, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from consulting and treating physicians. All files, memoranda, records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Any & all dental records, billing statements & copies of films. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 14418-L28 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, 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: 03/07/2011 MCS on behalf f /S/ evan Alac 'J'; EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L29 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 VS. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for 2IN BERT AND VALLEY FAME N PHYS (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you*ar?e ordered by the court to produce the following documents or things: ****SEE ATTACEED at 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: EVAN BLACK. E ADDRESS: 305 N. FRONT ST TELEPHONE: (715) 246-Mu SUPREME COURT ID #: ATTORNEY FOR: Defendant AR 0'9, 201. Date: Seat of the Court BY THE COURT- Pro Jerk, tary/CCivil Division Deputy 14418-29 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND VALLEY FAMILY PHYS. 757 NORLANDS AVENUE STE-101 CHAMBERSBURG, PA 17201 RE: MCS # 14418-L29 MICHELE A. NATALE 240 MINNICH ROAD CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 Please provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EMG's, MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Including records from Drs. Paul J. Quesenberry, & Anthony E. Patterson Prior approval is required for fees in excess of $150.00 for hospaws, $100.00 for all other providers. MCS # 14418-L29 SU10 n t CERTIFICATE t. amt g - k - N P REREQUISITE TO SERVICE OF A SUBPOE e AAk .-I' % PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS 0 As a prerequisite to service of a subpoena for documents and things jawuam --I to Rule 4009.22 tt1? » -'C-q X = r- !- rn cny C:?° Z! -q < ~C MCS on behalf of EVAN BLACK, ESQ. L? certifies that N --Irn (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: 03/07/2011 MCS on behal // /S/ evan Mach, e3a. EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L24 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: MICHELE A. NATALE -VS- BRICE D. ARNDT, DDS COURT OF COMMON PLEAS TERM, CASE NO: 07-6904 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DR. NICOLE M. YINGLING, MEDICAL, BILLING, AND X-RAY(S) TO: JEFFREY T. MCGUIRE, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, 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: 02/14/2011 CC: EVAN BLACK, ESQ. JEFFREY T. MCGUIRE, ESQ. CALDWELL & KEARNS 3631 N. FRONT STREET HARRISBURG, PA 17110333 TT&H 355-91452 MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 14418-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MICHELE A. NATALE File No. 07-6904 vs. BRICE D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. NICOLE M YINGLING, (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 Cg=_ Inc., 1601 Market Street, Suite 800 P lladclphia. 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: EVAN BLACK, ES ADDRESS: 305 N. FRONT STF TELEPHONE: (215) 746-090 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY liffi COURT: TAR U 2011 "Vi-othonotary/Cly k, Civil Division Deputy Date: (9, Seml,of the Court 14418-24 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. NICOLE M. YINGLING, GETTSBURG ENDODONTICS,P.C 1759 YORK ROAD GETTYSBURG, PA 17325 RE: MCS # 14418-L24 MICHELE A. NATALE 240 MINNICH ROAD CHAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date of Birth: 03-22-1965 Please provide entire medical, billing, and diagnostic file from 02-01-2008 to the present, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EMG's, MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 14418-L24 SU10 f IN THE MI BRICE As a to R CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 OF: A. NATALE -VS - ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 >. ARNDT, DDS ?erequisite to service of a subpoena for documents and things Sint '-y= 4009.22 -'''rrl C; ' ?? »a CJ C]C+ rf MCS on behalf of EVAN BLACK, ESQ. --311 certifies that (7 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, (1) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (1) 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: 04/04/2011 MCS on behalf of /S/ evan Mach. 6.a. EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L31 DE11 r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, -VS- CASE NO: 07-6904 BRICE 14. ARNDT, DDS THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DR. KI & FRANKLIN CO ENT MEDICAL, BILLING, AND X-RAY(S) SALLY UPTON, DDS. MEDICAL, BILLING, AND X-RAY(S) DR. LE R. CARRASCO MEDICAL, BILLING, AND X-RAY(S) SANDER WHITE, D.D.S. MEDICAL, BILLING, AND X-RAY(S) TO: JEFFREY T. MCGUIRE, ESQ., PLAINTIFF COUNSEL MCS on behalf of EVAN BLACK, 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 att ched counsel card and returning same to MCS or by contacting our local MCS office. DATE: 013/15/2011 MCS on behalf of EVAN BLACK, ESQ. Attorney for DEFENDANT CC J BLACK, ESQ. JEFFREY T. MCGUIRE, ESQ. CALDWEL & KEARNS 3631 N. FRONT STREET HARRISBURG, PA 17110333 TT&H 355-91452 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 14418-COl nrn') COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO: C A. NATALE File No. 07-6904 vs. D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 of Records for DR KIM A FRANKLIN O ENT (Name of Person or Entity) Within twen (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. hiladell2hia. 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 ad ance, the reasonable cost of preparing the copies or producing the things sought. If you fail to roduce the documents or things required by this subpoena within twenty (20) days after its service, the party serv' g this subpoena may seek a court order compelling you to comply with it. THIS S NAME: ADDRESS SUPREME C ATTORNEY WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: EVAN BLACK. ES HAMSBURG, PA 17101 (215) 246-0900 )URT ID #: 'OR: Defendant r4W THE COURT: rothonotar /Clerk, Civil Division Date: RAC' '4 I4 201f Seal of the Court Deputy 14418-31 EXPLANATION OF REQUIRED RECORDS TO: COSTODIAN OF RECORDS FOR: DR. K M & FRANKLIN CO ENT 755 N RLAND AVE SUITE 202 CHAMB?RSBURG, PA 17201 RE: CS # 14418-L31 MICHELE A. NATALE 40 MINNICH ROAD HAMBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date Of Birth: 03-22-1965 Pleas provide entire medical, billing, and diagnostic file from 11-01-2010 to the present, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten record and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EEG's, MRI's, and x-rays and all corresponding reports or inventories. This should contai all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. INCLUDING PATHOLOGY. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 14418-01 SUN CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MI . OF: A. NATALE -VS- COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 BRICE P. ARNDT, DDS As a p erequisite to service of a subpoena for documents and things pursuant to Rul 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that ( ) 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, (1) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (1) 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: Q4/04/2011 MCS on behalf of /S/ evan Alach, esa. EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L32 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND A.NATALE vs. File No. 07-6904 BRI E D. ARNDT, DDS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SALLY GU TON. DDS. (Name of Person or Entity) Within twen (20) days after service of this subpoena, you are ordered by the court to produce the following documents o things: * * * * SEE ATTACHED RIDER * * * * at You may del ver or mail legible copies of the documents or produce things requested by this subpoena, together with the certi icate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad ance, the reasonable cost of preparing the copies or producing the things sought. If you fail to roduce the documents or things required by this subpoena within twenty (20) days after its service, the party serv ng this subpoena may seek a court order compelling you to comply with it. THIS NAME: ADDRESS: SUPREME C, ATTORNEY Date: A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: EVAN BLACK. ESO -305-N. FRONT STREET PO BOX 999 -IARRiSBURG, PA 17101 (215) 246-0900 )URT ID #: OR: Defendant BY COURT: notary/Clerk, Civil Division rA ' 0 4 20% 3?ai- Seal of the Court Deputy 14418-32 EXPLANATION OF REQUIRED RECORDS TO: CI?STODIAN OF RECORDS FOR: SALLY UPTON, DDS. 467 PENNSYLVANIA AVENUE STE 10 FORT WASHINGTON, PA 19034 RE: M CS # 14418-L32 MICHELE A. NATALE 240 MINNICH ROAD C MBERSBURG, PA 17201 Social Security #: XXX-XX-1649 Date o Birth: 03-22-1965 Please provide entire medical, billing, and diagnostic file, including but no limited to any and all records, correspondence to and from the consul ing and treating physicians. Include all files, memoranda, handwritten record and notes, history and physical reports. Supply all medication and prescr ption records, medical billing and payment information. Provide all diagno tic films and tests, including CAT scans, CT scans, EEG's EKG's, EEG's, MRI's, and x-rays and all corresponding reports or inventories. This should contai all records in your possession, all archived records, or records in storag . Including any and all items as may be stored in a computer database or oth rwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 14418-L32 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS MICHELE A. NATALE TERM, CUMBERLAND -VS- CASE NO: 07-6904 BRICE D. ARNDT, DDS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that 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, () A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (1) No objection to the subpoena has been received, and (?) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/04/2011 MCS on behalf of / S / evan 121ach, en. EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-03 DE11 COMMONWEALTH OF.PENNSYLVANIA COUNTY OF CUMBERLAND A. NATALE vs. File No. 07-6904 BRI E D. ARNDT, DDS : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. LEER A RA O (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents o things: * * * * SEE ATTACHED RIDER at The ICS Grotip Inc.. 1601 Market S I P 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 ad ance, the reasonable cost of preparing the copies or producing the things sought. If you fail to the party sen THIS NAME: ADDRESS SUPREME C ATTORNEY Date: duce the documents or things required by this subpoena within twenty (20) days after its service, this subpoena may seek a court order compelling you to comply with it. A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: EVAN BLACK ESO 305 N. FRONT STREET PO BOX 999 HAM B R , PA 17101 (215) 246-0900 )URT ID #: `APR `p 4 2011. BY COURT: ry/Cler , Civil Division Deputy Seal of the Court 14418-33 EXPLANATION OF REQUIRED RECORDS TO: COSTODIAN OF RECORDS FOR: DR. L E R. CARRASCO PENN EDICINE AT RADNOR 250 K NG OF PRUSSIA PA 19087 RE: S # 14418-03 MICHELE A. NATALE 40 MINNICH ROAD HAMBERSBURG, PA 17201 Socia Security #: XXX-XX-1649 Date Of Birth: 03-22-1965 Pleas provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten record and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EEG's, MRI's, and x-rays and all corresponding reports or inventories. This should contai all records in your possession, all archived records, or records in storag Including any and all items as may be stored in a computer database or oth rwise in electronic form. INCLUDING PATHOLOGY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 14418-03 SUM CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATT :R OF: MICHEL A. NATALE -VS- BRICE P. ARNDT, DDS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-6904 As a p erequisite to service of a subpoena for documents and things pursuant to Rul 4009.22 MCS on behalf of EVAN BLACK, ESQ. certifies that (4 ( ) 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, () A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (1) No objection to the subpoena has been received, and The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/04/2011 MCS on behalf of /S/ evan glach, EVAN BLACK, ESQ. Attorney for DEFENDANT MCS # 14418-L34 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND A. NATALE vs. D. ARNDT, DDS File No. 07-6904 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: of Records for SANDER WHITF D.D.S. (Name of Person or Entity) Within twen (20) days after service of this subpoena, you are ordered by the court to produce the following documents o things: * * * * SEE ATTACHED RIDER at The i-CS Group. Inc.. 601 Market Street, Suite 800 hiladell2hia. PA 19103 You may delver or mail legible copies of the documents or produce things requested by this subpoena, together with the certi icate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad ance, the reasonable cost of preparing the copies or producing the things sought. If you fail to roduce the documents or things required by this subpoena within twenty (20) days after its service, the party serv ng this subpoena may seek a court order compelling you to comply with it. THIS SUBP ENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: EVAN BLACK. ESO ADDRESS: 305 N. FRONT T FFT PO BOX 999 HARRISBURG, PA 17101 TELEPHON : (215) 246-0900 SUPREME COURT ID #: ATTORNEY OR: Defendant :BY DC OURT: ry/Clerk, Civil Division APR _O 4.20111 < Deputy Date: Seal of the Court 14418-34 EXPLANATION OF REQUIRED RECORDS TO: CPSTODIAN OF RECORDS FOR: SANDE WHITE, D.D.S. 2193 EST CHESTER PIKE L, PA 19008 RE: CS # 14418-L34 ICHELE A. NATALE 40 MINNICH ROAD HAMBERSBURG, PA 17201 Socia Security #: XXX-XX-1649 Date f Birth: 03-22-1965 Pleas provide entire medical, billing, and diagnostic file, including but n t limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten recor s and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EMG's, MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or oth rwise in electronic form. INCLUDING PATHOLOGY Prior approval is required for fees in excess of $150.00 for hospitals, $100,00 for all other providers. MCS # 14418-04 SU10 Jeffrey T. McGuire, Esquire - ILL -OFFICE Pi 0THONOTARy PA I.D. # 73617 ld ll & K C P C J 12 a we earns, . . AM 11: 50 3631 North Front Street 17110-1533 U NNS AND LVAN A? (717) 232-7661 I Fax: (717) 232-2766 Attorney for Plaintiff. Michele C. Natale MICHELE C. NATALE, In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania V. BRICE D. ARNDT, DDS, Defendant NO. 07-6904 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY OF SAID COURT: Please mark the above-captioned Date: July 11, 2011 By: discontinued and ended with prejudice. T. NjeGuire, Esquire v . #73617 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 (717) 232-2766 (Fax) Attorney for Plaintiff, Michele C. Natale 07439-1-179145 CERTIFICATE OF SERVICE AND NOW, this 11th day of July 2011, 1 hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: F. Evan Black, Esquire THOMAS, THOMAS & HAFER, LLP P.O. Box 999 Harrisburg, PA 17108 CALDWELL & KEARNS By: Wl.