HomeMy WebLinkAbout06-10-03 IN RE:
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
APPOINTMENT OF A GUARDIAN :
OF THE PERSON OF :
MILDRED J. GERBER, : ORPHANS COURT DIVISION
an alleged incapacitated person, :
Respondent : No. 21-01-92
REQUEST FOR PRODUCTION OF DOCUMENT£
TO: MARILYN J. GERBER
% Stanley J. Laskowski, Esquire
Caldwell & Kearns
3631 N. Front Street
Harrisburg, PA 17110
Pursuant to Pa. R.C.P. No. 4009, as amended, the Respondent by his
attorneys, Rupp and Meikle, request you to produce copies of the following
documents, at their expense, within thirty (30) days of service of this Request.
INSTRUCTION.~
If you object to the production of any document on the grounds that
the attorney-client, attorney work-product or any other privilege is
applicable thereto, you shall, with respect to that document:
(a) State its date;
(b) Identify its author;
(c) Identify each person from whom the document was received;
(d) Identify each person who received it;
(e) Identify each person from whom the document was received;
(f) State the present location of the document and all copies
thereof;
(g) Identify each person who has ever had possession, custody or
control of it or a copy thereof; and
(h) Provide sufficient information concerning the document and the
circumstances thereof to explain the claim of privilege and to
permit the adjudication of the propriety of that claim.
As referred to herein, "document" includes written, printed, typed,
recorded, or graphic matter, however produced or reproduced, including
correspondence, telegrams, other written communications, data processing
storage units, tapes, contracts, agreements, notes, memoranda, analyses,
projections, indices, work papers, studies, reports, surveys, diaries,
calendars, films, photographs, diagrams, drawings, minutes of meetings, or
any other writing including copies of any of the foregoing, regardless of
whether you are now in possession, custody, or control, your former or
present counsel, agents, employees, officers, insurers, or any other person
acting on your behalf.
DOCUMENTS RE(~UESTE~n
1. Please produce all documents referred to in your Answers to
Interrogatories from Respondent to Petitioner in Petitioner's Petition to
Vacate Order and Review Hearing Related to Access Visits of Petitioner
with Petitioner's Mother.
2. Please provid, e all documents you intend to introduce at the February
6, 2003 hearing.
3. Please produce all statements of witnesses you have obtained with
respect to all matters raised in Petitioner's Petition to Vacate Order
and Request Review Hearing·
4. Please provide all statements of experts you intend to introduce at the
hearing on February 6, 2003.
Respectfully submitted.
Attorney I.D. #34832
355 N. 21st St., Suite 205
Camp Hill, PA 17011
(717) 761-3459
Attorney for Respondent
CERTIFICATE OF SERVICE
I, Richard C. Rupp, Esquire, do hereby certify that I am serving a true
and correct copy of the foregoing Request for Documents upon the person(s)
named below by hand delivery. ~~ ~
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Attorney I.D.# 34832
355 North 21 st Street, Suite 205
Camp Hill, Pennsylvania 17011
(717) 761-3459
Dated: January 2, 2003