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HomeMy WebLinkAbout04-0145 ORIGINAL RICHARD BOTTORF, JR AND BRENDA BOTTORF, His Wife Plaintiffs : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNA. v. : CIVIL ACTION - LAW C-,....- : NO. 04 - I'I~ C/O.l C l~~ : JURY TRIAL DEMANDED JENNIFER SHARAR Defendant 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 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 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una aparlencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELEPFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland COW1ty Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 269511.1IMEKIMMM RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiffs : IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA v. : CIVIL ACTION - LAW (] l~ : NO. 04. - Llo'l l~ : JURY TRIAL DEMANDED JENNIFER SHARAR Defendant COMPLAINT I. Plaintiffs Richard and Brenda Bottorf are husband and wife adult individuals who reside at 810 Sherwood Road, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant Jennifer Sharar is an adult individual who resides at 734 Harding Street in New Cumberland, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on January 21, 2002 at approximately 10:00 a.m. on Brandt Avenue in New Cumberland, Cwnberland County, Pennsylvania. 4. At that time and place, Plaintiff Richard Bottorf, Jr. was operating his 2001 Monte Carlo, South on Brandt Avenue. 5. Brandt Avenue in the location of the accident is a two-lane residential street with a posted speed limit of25 miles per hour. 6. At that time and place, Defendant Jennifer Sharar was operating her parents' car north on Brandt Avenue. 7. At the time of the accident, Brandt A venue was snow covered, and it was snowing. 8. Defendant Jennifer Sharar was travelling too fast for conditions and lost control of her car. _._......._-~-_._,.~-'"" - 9. As Defendant Jennifer Sharar was passing in the opposite direction of the Plaintiff Richard Bottorf, Jr., she crossed over the center line of the street and struck Plaintiff Richard Bottorf, Jr.' s vehicle in the driver's side door and pushed Plaintiff's car into the grass field. 10. As a result of the violent collision, Richard Bottorf, Jr.'s car was pushed off the highway causing heavy damage resulting in Plaintiff Richard Bottorf sustaining serious personal injuries. 11. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiffs Richard and Brenda Bottorf are the direct and proximate result of the negligent, careless and reckless manner in which Defendant Jennifer Sharar operated her motor vehicle as follows: (a) failure to have her vehicle under such control as to be able to stop within the assured clear distance ahead; (b) failure to stay within her own lane of travel; (c) failure to travel at a safe and appropriate speed given the weather conditions which existed at the time of the accident; (d) failing to remain in her proper lane of travel and crossing over the center line resulting in a collision with Plaintiff's vehicle; ( e) failure to keep proper and adequate control over her vehicle; and (f) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLAIM I RICHARD BOTTORF, JR. V. JENNIFER SHARAR 12. Paragraphs 1 through 11 are incorporated herein by reference. 269511.1IMEKIMMM 13. Plaintiff Richard Bottorf, Jr. sustained painful and severe injuries which include but are not limited to, a whiplash injury and injury to his neck, limitations in range of motion as well as contusions and abrasions about his body. 14. By reason of the aforesaid injuries sustained by Richard Bottorf, Jr., he was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore himself to health, and claim is made therefor. 15. Because of the nature of his injuries, Richard Bottorf, Jr. has been advised and, therefore, avers that he may be forced to incur similar expenses in the future, and claim is made therefor. 16. As a result of the aforementioned injuries, Richard Bottorf, Jr. has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out his daily activities, loss oflife's pleasures and enjoyment, and claim is made therefor. 17. As a result of the aforementioned injuries, Richard Bottorf, Jr. has sustained work loss, loss of opportunity and a permanent diminution of his earning power and capacity, and claim is made therefor. WHEREFORE, Plaintiff Brenda Bottorf demand judgment against Defendants Sharar in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. CLAIM II BRENDA BOTTORF V. JENNIFER SHARAR 18. Paragraphs 1 through 17 of the Complaint are incorporated herein by reference. 269511.1 IMEK\MMM 19. As a result of the aforementioned injuries sustained by her husband, Richard Bottorf, Jr. Brenda Bottorf has been and may in the future be deprived of the care, companionship, consortium, and society of her husband, all of which will be to her great detriment, and claim is made therefor. WHEREFORE, Plaintiff Brenda Bottorf demand judgment against Defendants Sharar in an amount in excess of Twenty-Five Thousand ($25,000.00) Dollars exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ,P.c. ..... ichael E. Kosik J.D. No. 36513 4503 N. Front Street Harrisburg, PAl 7 I IO (717) 238-6791 Attorney for Plaintiff 269511.1 IMEK\MMM VERIFICATION I, RICHARD BOTTORF, JR., do swear and affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unswom falsification to authorities. WITNESS: ;3undf))~ Dated: /.2 //5 )n.3 '<l N (::l en tt- 'i 0 -. Crt '" ~ -.0 () ~~~ t --<-- ~" ---4 L. ~..~...,..... ~....~~ i~1 ~l~ e C) ~:~ ~~ ( - . ,-j ._u f f'-,'. _ s~:) . , - l.e"' c.," ._,- SHERIFF'S RETURN - REGULAR CASE NO: 2004-00145 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BOTTORF RICHARD JR ET AL VS SHARAR JENNIFER RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHARAR JENNIFER the DEFENDANT at 1511:00 HOURS, on the 13th day of January 2004 at 734 HARDING STREET NEW CUMBERLAND, PA 17070 by handing to AMY SHARAR, SISTER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: lS.00 11.73 .00 10.00 .00 39.73 ,// .~.<-'~,,_.t::,;.~ .' R. Thomas Kline 01/14/2004 ANGINO & ROVNER Sworn and Subscribed to before By: me this ;(~ au)... day of ( ~J .;2ov'l A.D. \. li~ (2, rn.uj~ ~, / Prothonotary , RICHARD BOTTORF, JR. and BRENDA BOTTORF, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04-145 Civil Term JENNIFER SHARAR, Defendant JURY TRIAL DEMANDED CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Jennifer Sharar, with regard to the above-captioned matter. Respectfully submitted, By: NEALON & GOVER, P.C. ::..-:;; ~~ Andrew C. Lehman, Esquire I.D. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date;Yf/4y CERTIFICATE OF SERVICE AND NOW, this i/X I" day of February, 2004, I hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael E. Kosik, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 --~--. -- ~ ~ Andrew C. Lehman, Esquire 8 ~ '"Om ['~LT~ Z't::~ UJ J~~+ -/ ,,: rO" .........::\,- ~(J ~2 ~ "'" = = ..r:- ...., ,.., 0'.) I U1 ~ .-1 :I:n ~,...~ 'U -:;;. '-1., I:i:J 9-0 om -I :5J -< ...., ::ll:: ~ .s:- RICHARD BOTTORF, JR. and BRENDA BOTTORF, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-145 Civil Term JENNIFER SHARAR, Defendant JURY TRIAL DEMANDED CIVIL ACTION - LAW NOTICE TO PLEAD TO: Richard Bottorf, Jr. and Brenda Bottorf C/o Michael E. Kosik, Esquire ANGINO & ROVNER, P,C. 4503 North Front Street Harrisburg, PA 17110 YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GOVER, P.C. --?- ~.... By: Andrew C. Lehman, Esquire 1.0. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 D,te t1$d~ RICHARD BOTTORF, JR. and BRENDA BOTTORF, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-145 Civil Term JENNIFER SHARAR, Defendant JURY TRIAL DEMANDED CIVIL ACTION - LAW ANSWER WITH NEW MATTER 1 -7. Admitted. 8. Denied pursuant to Pa. RCP. 1029(e). 9-10. Denied as stated. However, it is admitted that on the date and time as stated in Plaintiffs' Complaint, a motor vehicle accident occurred between the vehicle being operated by Defendant and the vehicle being operated by Plaintiff Richard Bottorf, Jr. The remaining averments contained in these paragraphs are denied pursuant to Pa. RC.P.1029(e). 11. Said paragraph and all of its subparts are denied pursuant to Pa. RC.P. 1029(e). CLAIM I RICHARD BOTTORF, JR. V. JENNIFER SHARER 12. Paragraphs 1 through 11 are incorporated herein by reference thereto as if set forth at length. 13 - 17. Denied as after reasonable investigation Defendant is without sufficient knowledge or information as to form a belief as to the truth of the matter asserted and proof is demanded at trial. Any remaining averments contained in these paragraphs are denied pursuant to Pa. R.CP. 1029(e). CLAIM II BRENDA BOTTORF V. JENNIFER SHARAR 18. Paragraphs 1 through 17 are incorporated herein by reference thereto as if set forth at length. 19. Denied as after reasonable investigation Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter asserted and proof is demanded at trial. Any remaining averments contained in this paragraph are denied pursuant to Pa. R.C.P. 1029(e). NEW MATTER 20. Paragraphs 1 through 19 are incorporated herein by reference thereto as if set forth at length. 21. Plaintiffs' claims may be barred in whole or in part by application and operation of the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Defendant respectfully requests the within Complaint be dismissed with costs as allowed by law. Respectfully submitted, NEALON & GOVER, P.C. --.,. By: Andrew C. Lehman, Esquire 1.0. #: 81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: t5? (;91Oy VERIFICATION I, Jennifer Sharar, verify that the statements made in the foregoing ANSWER WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.SA S4904 relating to unsworn falsification to authorities. Date: P/llo/0tj ~~ 8hnnnn J NNIF R SHARAR CERTIFICATE OF SERVICE AND NOW, this J.2..!f:;;FebrUary, 2004, I hereby certify that I have served the foregoing ANSWER WITH NEW MATTER on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael E. Kosik, Esquire ANGINa & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 ". 0 '" r; <:;':.") 0 C;.;,') " -<- " .." =j:! r-i~l C:> r1i:tJ ".0 c-- -Z:'I--:--' , a "'''7 ~-.J .~'O ~'.;J 5r; c~ ~'Y {5i~ > '. ..,.. 5,:;.' -<; .~-L1 Co -~ RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiffs IN THE COURT OF COMON PLEAS OF CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW : NO. 04-145 CIVIL TERM JENNIFER SHARAR Defendant : JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER AND NOW come the Plaintiffs, by and through their attorneys, Angino & Rovner, P.c., and hereby replies to the New Matter of Defendant as follows: 20. Pennsylvania Rules of Civil Procedure 1030 provides that a party may set forth as New Matter any material facts which are not merely denials of the averments of the preceding pleading. A review of Defendant's Answer to Plaintiff's Complaint does not disclose any factual averments other than admissions or denials of the corresponding paragraphs of Plaintiffs' Complaint. Therefore, Defendant's incorporation of their Answer to Plaintiffs' Complaint as New Matter is improper and no further response is required. 21. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that any of Plaintiffs' claims are barred in whole or in part by the application of the Pennsylvania Motor Vehicle Financial Responsibility Law. By way of further response, Defendant's attempted incorporation of any and all possible defenses which may arise from the Pennsylvania Motor Vehicle Financial Responsibility Law is improper. Pennsylvania Rules of Civil Procedure 1019 provides that the material facts upon which a defense is based shall be stated in a concise and summary form. Defendant's incorporation of all of the Pennsylvania Motor Vehicle Financial Responsibility Law as a defense does not alert the Plaintiff to which, if any, of the provisions may 272523.1IMEK\MMM be applicable and therefore is an ineffective attempt to assert a defense since it does not adequately place Plaintiffs on notice specifically which defenses Defendant is attempting to take advantage of. WHEREFORE, Plaintiffs respectfully requests that this Honorable Court dismiss Defendant's New Matter enter judgment in favor of Plaintiffs and against Defendant. /' ER, P.c. ichael E. Kosik, Esquire J.D. No. 36513 4503 N. Front Street Harrisburg, P A 1711 0 (717) 238-6791 Counsel for Plaintiff DATED: 2/24/04 272523.1IMEKIMMM I COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF DAUPHIN I, MICHAEL E. KOSIK, ESQUIRE, being duly sworn according to law, deposes and states that I am counsel for Plaintiffs, that I am authorized to make this Affidavit on behalf of said Plaintiffs, and that the facts set forth in the foregoing Reply to New Matter, are true and correct to the best of my knowledge, information and belief. C Michael E. Kosik Sworn to and subscribed before me this C \~ day -\ of l..zo"~' I..,", , 2004. ~ r . l .fS. !,,,,, '\. / ~t \AC ,) Notary Public My Commission Expires: ~j '\ 1.-1 (~l f NOTARIAL SEAL BRYDON H. lIDlE, III, NOTARY PUBLIC CITY OF HA ISBURG, DAUPHIN COUNTY MY COMMI N XPIRE MARCH 4 2006 68991/LRJ CERTIFICATE OF SERVICE AND NOW, this 24th day of February, 2004 I, Michelle M. Milojevich, an employee of Angino & Rovner, P.C., do hereby certify that I have served a true and correct copy of the PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER in the United States mail, postage prepaid at Harrisburg, Pennsylvania, addressed as follows: Andrew C. Lehman, Esquire Nealon & Gover, P.C. 24 II North Front Street Harrisburg, PA 17110 7n 11LL( 1.1 ))') . (Ju ~ Michelle M. Milojevich -.--.... 68991/LRJ r, c: ::J -( - "" c-:, LJ ~- ."'1 p.o.; Ci"J ,-,... Ui N CoO) W CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04 -14 5 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No obj ection 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: 03/22/2004 DEll-480898 42535 -LO 1. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-145 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 IRON RIDGE FAMILY PRACTICE ORTHOPEDIC INSTITUTE OF PA. HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL KEYSTONE SPINE CENTER MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAyg TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/02/2004 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 04 -069 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-2578244253S-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RICHARD BOITORF, JR. AND BRENDA BOITORF : FileNo. 04-145 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for IRON RIDGE F AMIL Y PRACTICE (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 A IT ACHED RIDER .... at The MCS GroUD Ine 1601 Market Street Suite ROO Philadelnhia 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 TIIE FOLLOW1NG PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISB1JRG.PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: AITORNEY FOR: Defendant BY TIIE COURT: /s/~.z. /' ~~ Prothonotary/Clerk, Civil ivision Date: MAR 2 2 2004 c.::ht . d'/. d~~ ~/AA4 Y' ~~ ~ Seal of the Court A")(;'}':;: (\1 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: IRON RIDGE FAMILY PRACTICE 880 POPLAR CHURCH RD. CAMP HILL, PA 17011 RE: 42535 RICHARD E. BOTTORF, JR. INCLUDING DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic fIle, including but not limitl~d 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: RICHARD E. BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 8U10-491030 42535 -LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-145 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on tlehal f of DATE: 03/22/2004 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT D1~11-480899 42535 -LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04 -14 5 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 IRON RIDGE FAMILY PRACTICE ORTHOPEDIC INSTITUTE OF PA. HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL KEYSTONE SPINE CENTER MEDICAL RECORDS " XIU,YS MEDICAL RECORDS " XRJ~S MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS " XRAYS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing tbe attacbed counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/02/2004 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 04-069 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET D800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-257824 42535 - C 0 ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RICHARD BOTIORF, JR. AND BRENDA BOTIORF : FileNo. 04-145 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPEDIC INSTITUTE OF PA. (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 ATIACHED RIDER ***" at The MCS Grann Jne ]60] Markel Street Snite 800 Philadelphia FA 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. TIllS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOllvING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATIORNEY FOR: Defendant BY THE COURT: /sl /L~' ~ ~~ Prothonotary/Clerk, Civi IVlSlon Date: MAR 2 2 2004 '01d o?'-/. .;?~-'/ ~"~A4i ~ -0k ~ Deputy/ Seal of the Court Ll'),1.,_()') EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA. 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 42535 RICHARD E. BOTTORF, JR. INCLUDING ALL DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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, mes, 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 pe11aining to: Dates Requested: up to and including the present. Subject: RICHARD E. BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, ]~A 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 SU10-491032 42535-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-145 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the Bubpoena is sought to be served, (2) A copy of the notice of intent. including tie proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/22/2004 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-480900 42535-L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04 -145 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AlO> THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 IRON RIDGE FAMILY PRACTICE ORTHOPEDIC INSTITUTE OF PA. HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL KEYSTONE SPINE CENTER MEDICAL RECORDS , XRJ~S MEDICAL RECORDS , XRJ~S MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS , XRl,YS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREi! C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice.. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/02/2004 MCS on behalf of ANDREi! C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREi! C. LEHMAN, ESQ. - 04-069 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 ]]IE02-257824 42 S3 S -CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND roCRMrnBOTIO~,ffi.MIDB~NDABOTIO~: FileNo. 04-]45 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT 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: u** SEE ATIACHED roDER **** at The MCS Group Ine 1601 Market Street. Suite 800 Philadelnhia 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 ~QUEST OF THE FOLLOWING PERSON: NAME: ADD~SS: MID~W C. LEHMAN. ESO. 2411 N FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (2] 5) 246-0900 SUP~ME COURT ID #: ATIORNEY FOR: Defendant BY THE COURT: /5/ ~~ /~~ Prothonotary/Clerk, Civil D' tSlOn Date: MAR 2 2 2004 c;/~ Ol~ dtf//7<1/ ~~""~~ ~Y~9Y' Deputyi/ Seal of the Court II'lC')C A') EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 42535 RICHARD E. BOTTORF, JR. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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 re:strictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: RICHARD E. BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, J>A 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 8010-491034 42535-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04 -14 5 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/22/2004 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-480901 42535-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-145 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 IRON RIDGE FAMILY PRACTICE ORTHOPEDIC INSTITUTE OF PA. HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL KEYSTONE SPINE CENTER MEDICAL RECORDS & XRJIYS MEDICAL RECORDS & XRJIYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRJ~YS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one tbat is attacbed 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 y'Jur expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/02/2004 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 04-069 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-257824 42535 - C 01 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND RICHARD BOTTORF, JR. AND BRENDA BOTTORF : FileNo. 04-145 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT 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 TheMCSGroup Ine 160] MarkelStreel SU;le800 Philadelnh;a 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 ,;omply with it. TIllS SUBPOENA WAS ISSUED AT TIlE REQUEST OF TIlE FOLLOWING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT S1REET HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant BY TIlE COURT: /5/ dd. "P ~~ Prothonotary/Clerk, Civil IVlSlOn Date: MAR 2 2 2004 $I-..d. J~ c2~<Y' ~?./",,4.. r~ ~ Depu!#, Seal of the Court I'I""1C.,C A/I EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 42535 RICHARD E. BOTTORF, JR. INCLUDING ALL DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: RICHARD E. BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, I>A 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 SU10-491036 42535-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04 -14 5 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/22/2004 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-480902 42535 -LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-145 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Rl:rr.E 4009.21 IRON RIDGE FAMILY PRACTICE ORTHOPEDIC INSTITUTE OF PA. HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL KEYSTONE SPINE CENTER MEDICAL RECORDS & XR1IYS MEDICAL RECORDS & XR1IYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XR1\yg TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS off ice. DATE: 03/02/2004 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. - 04-069 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IlE02-25782442S3S-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RlCHARD BOTTORF, JR AND BRENDA BOTTORF : FileNo. 04-145 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KEYSTONE SPINE CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RlDER "*** at The MCS Grouo Joe 1601 Market Street Suite 800 Phi]adelphia PA ]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. TIllS SUBPOENA WAS ISSUED AT TIlE REQUEST OF TIlE FOLLOWING PERSON: NAME: ADDRESS: ANDREW C. LEHMAN. ESO. 2411 N. FRONT S1REET HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant BY THE COURT: /:'C/ Ce~./~ Prothonotary/Clerk, Civil Di lsion Date: MAR 2 2 2004 c:Y-..d. c:?7': 07L'OV DepU~~-r.7 ~ ~ 95' Seal of the Court A"ll;:-:JC f\'::' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KEYSTONE SPINE CENTER 1521 CEDAR CLIFF DRIVE CAMP HILL, PA 17011 RE: 42535 RICHARD E. BOTTORF, JR. INCLUDING ALL DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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 physiical 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 fo:rm, relating to any examination, consultation, diagnosis, care or treattnent pertaining to: Dates Requested: up to and including the present. Subject: RICHARD E. BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 8U10-491038 42535 -LO 5 8 ~ :!2C,','" y,:.Y......f 0~ kO ,;l:>c, if:d -("- z ::;} "" "" = ~ ::J: ):>0 ::0 '" en o -., 5'! m:!l ~a ~~ 0"", 7"''' Om '" T"-'> ~ :boo ::s:: 9 ~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-145 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/01/2004 DEll-483238 42535 -LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMO N PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CAS E NO: 04 -14 5 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HEALTH SOUTH NEUROLOGY CENTER, INC. INTERNISTS OF CENTRAL PA, LTD MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/12/2004 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. JOSEPH VRANIC - 04-069 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259081 42535 -CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RlCHARD BOTTORF, JR. AND BRENDA BOTTORF : FileNo. 04-145 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOUTH (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 A IT ACHED RlDER **** at The MCS Graun Ine 1601 Market SITeet Suite 800 Philadelnhia 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: ANDREW C. LEHMAN. ESO. 24] 1 N. FRONT STREET HARRISBURG PA 17110 TELEPHONE: (2]5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Prothonotary/Clerk, Civil Div' . ~()-'>oo . [? 7rzr~~ Deputy "-- Date: frl':l./J,..L.. P, ~c>oy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH 840 NORTH FRONT STREET WORMLEYSBURG, PA 17043 RE: 42535 RICHARD E. BOTTORF, JR. INCLUDE DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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: RICHARD E. BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 SU10-493096 42535-L06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-14 5 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 04/01/2004 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-483239 42535-L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS - CASE NO: 04 -14 5 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HEALTH SOUTH NEUROLOGY CENTER, INC. INTERNISTS OF CENTRAL PA, LTD MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an Objection to the subpoena. If the twenty day notice period is waived or if no Objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/12/2004 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. JOSEPH VRANIC - 04-069 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259081 42535-CO~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RlCHARD BOTIORF, JR. AND BRENDA BOTIORF : FileNo. 04-145 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NEUROLOGY CENTER. INC. (Name ofperson 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 ATIACHED RlDER **** at The MCS Groun Ine 1601 Market Street Suite 800 Philadelnhia 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: ANDREW C. LEHMAN. ESO. 2411 N FRONT STREET HARRISBlJRG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: A TIORNEY FOR: Defendant Date: (Yl';Jt? (" h PI ;).fjXJy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NEUROLOGY CENTER, INC. 897 POPLAR CHURCH RD. SUITE 107 CAMP HILL, PA 17011 RE: 42535 RICHARD E. BOTTORF, JR. INCLUDE DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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 andlor 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: RICHARD E. BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 SU10-49309B 42535-L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04 -14 5 JENNIFER SHARAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ANDREW C. LEHMAN, ESQ. certifies that (I) 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: 04/01/2004 ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT DEll-483240 42535 -LO 8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RICHARD BOTTORF, JR. AND BRENDA BOTTORF TERM, -VS- CASE NO: 04-14 5 JENNIFER SHARAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2~ HEALTH SOUTH NEUROLOGY CENTER, INC. INTERNISTS OF CENTRAL PA, LTD MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MICHAEL E. KOSIK, ESQ., PLAINTIFF COUNSEL MCS on behalf of ANDREW C. LEHMAN, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/12/2004 MCS on behalf of ANDREW C. LEHMAN, ESQ. Attorney for DEFENDANT CC: ANDREW C. LEHMAN, ESQ. JOSEPH VRANIC - 04-069 Any questions regarding this matter, Contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-25908142535-C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RICHARD BOTTORF, JR. AND BRENDA BOTTORF : FileNo. 04-145 vs. JENNIFER SHARAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for INTERNISTS OF CENTRAL PA LTD (Name of Person or Entity) Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: .... SEE ATTACHED RIDER .... at TheMCSGroun Ine ]601 MarketS!reet Suite ROO 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: ANDREW C. LEHMAN. ESO. 24]] N. FRONT STREET HARRISBURG. PA ] 7] 10 TELEPHONE: (2]5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ~ t?[ :;,co! Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: INTERNISTS OF CENTRAL PA, LTD 108 LOWTHER STREET PO BOX 107 LEMOYNE, PA 17043 RE: 42535 RICHARD E. BOTTORF, JR. INCLUDE DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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 treaunent pertaining to: Dates Requested: up to and including the present. Subject: RICHARD E, BOTTORF, JR. 810 SHERWOOD ROAD, NEW CUMBERLAND, PA 17070 Social Security #: 168-48-3931 Date of Birth: 12-11-1959 SUIO-493100 42535-L08 ( . ,_'_,1 :;::-. .3 , ~ <:::> '" i;g "" ..... A. ::"J -0 I c.., :r-, -.~ <::) '"f1 Y f/'i;J] :-P,""t7 ..J? .- .J .~:r-i S-> ()"":h -~j.,q :1";1 '" II I. RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiffs : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNA. v. : CIVIL ACTION - LAW : NO. 04-145 CIVIL TERM JENNIFER SHARAR Defendant : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND TIDNGS FOR DISCOVE,RY PURSUANT TO RULE 4009.21 Plaintiff 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 no objection is made, the subpoena may be served. ichael E. osik, Esquire l.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238..6791 Counsel for Plaintiff DATED: 5/12/04 275824.11MEKIMMM COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiff/s versus JENNIFER SHARAR : No. 04-145 CIVIL TERM Defendant/s SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Bureau of Driver Licensing Driver Record Services PO Box 68695 Harrisburg, P A 17106-8695 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: driving record for Jennifer Sharar, driver's number 26273 0222 at Angino & Rovner, 4503 N. Front St., Hbg., P A 17110. 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 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: Michael E. Kosik 4503 North Front Street Harrisburg, P A 17110 (717) 238-6791 36513 Plaintiffs Telephone: Supreme Court ID #: Attorney for: BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy II. CERTIFICATE OF SERVICE I, Michelle M. Milojevich, of Angino & Rovner, P.C., do hereby certify that I have served a true and correct copy of the foregoing NOTICE OF INTENT TO SERVE A SUBPOENA upon defense counsel by United States mail, postage prepaid, addressl:d as follows: Andrew C. Lehman, Esquire Nealon & Gover, P.C. 2411 N. Front Street Harrisburg, PA 17110 .trlLl LJJJ 1m. ~ Michelle M. Milojevich Date: 5/12/04 275824.1IMEKIMMM . (") '" 0 = Sc~ c:.') ," x- '"'.:-.~ -. -l " t": ...... :c .,.., r(~; , :;l-.I'" rn -";" r- jj~ W "::J :--1 ~ -'...-l"j -r: ;)l~-j -'-" ~rn { ( ~:::t ::: ~. (J1 :'.ij, 0) ~- RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiffs : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNA. v. : CIVIL ACTION - LAW : NO. 04-145 CIVIL TERM JENNIFER SHARAR Defendant : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENAS PURSUANT TO RULE 4009.21 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff certifies that: (I) a notice of intent to serve a 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 was sought to be served, (2) a copy of the notice of intent, including the proposed subpoena is attached to this certificate, (3) no objection was filed with the court; (4) the subpoena which will be served is identical to the notice of intent to serve a subpoena. Dated: 7/12/04 275824.1IMEKIMMM RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiffs : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNA. v. : CIVIL ACTION - LAW : NO. 04-145 CIVIL TERM : JURY TRIAL DEMANDED 0 ~ ~.. 2~r'- 1.c'-'-' ....., = = JENNIFER SHARAR Defendant -ry -",,," o -n :..,-1 fn~ -OJ,1 :--ncr1 ()C) ::::!-':", t -~c::; ::::} ~-~f;~ ....::-~ ~:~ ::c ::::-'-" -.: (t', " NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE:~ DOCUMENTS AND THINGS FOR DISCOVJB:RY PURSUANT roi; P":"'- RULE 4009.21 ~ -J -.. w <..11 co Plaintiff 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 no objection is made, the subpoena may be served. R,P.C. /' ichael E.-Kosik, Esquire I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff DATED: 5/12/04 275824.IIMEKIMMM COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERl,AND RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiff/s versus JENNIFER SHARAR : No. 04-145 CIVIL TERM Defendant/s SUBPOENA TO PRODUCE DOCUMENTS OR TIDNGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Bureau of Driver Licensing Driver Record Services PO Box 68695 Harrisburg, P A 17106-8695 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: driving record fi)r Jennifer Sharar, driver's number 262730222 at Angino & Rovner, 4503 N. Front St., Hbg., PA 17110. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, togetber 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 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: Michael E. Kosik 4503 North Front Street Harrisburg, P A 1711 0 (717) 238-6791 36513 Plaintiffs Telephone: Supreme Court ID #: Attorney for: BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy II CERTIFICATE OF SERVICE I, Michelle M. Milojevich, of Angino & Rovner, P.C., do hereby certify that I have served a true and correct copy of the foregoing NOTICE OF INTENT TO SERVE A SUBPOENA upon defense counsel by United States mail, postage prepaid, addressed as follows: Andrew C. Lehman, Esquire Nealon & Gover, P.C. 2411 N. Front Street Harrisburg, PA 17110 '~11uWJJ --ln~ Michelle M. Milojievich ' Date: 5/12/04 275824.11MEKIMMM CERTIFICATE OF SERVJ[Q.; AND NOW, this Ii" day of July, 2004 I, Michelle M. Milojevich, an employee of Angino & Rovner, P.C., do hereby certify that I have served a true and correct copy of the CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPEOAN in the United States mail, postage prepaid at Harrisburg, Pennsylvania, addressed as follows: Andrew C. Lehman, Esquire Nealon & Gover, P.C. 2411 N. Front Street Harrisburg, P A 17110 tp/iJ/L JJ7'~~ Michelle M. Miloje ich 275824.lIMEKIMMM Q ~." 1~ ;_.~. ,-~lf ' .,<-c. ('.' ; !::;; ;~~~ J>(- ;? -< ....., = c=~ .r- L. C. r= o " jl ni7J r- -nfTl -r"'i f~~ <...:> " :JF. '>.' <,.) _":0 -< RICHARD BOTTORF, JR. and BRENDA BOTTORF, his wife, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. NO. 04-145 Civil Term JENNIFER SHARAR, Defendant JURY TRIAL DEMANDED CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, Jennifer Sharar, with regard to the above-captioned matter. Respectfully submitted, Date: 8~(t-oY NEALON & GOVER, P.C. .~//~;:;? ~. .... .'P.:;?' ".,. ",/ By: ~ / / --'-""" Andrew C. Lehman, Esquire 1.0.#:81937 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this ! ~ay of August, 2004, I hereby certify that I have served the foregoing PRAECIPE FOR WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael E. Kosik, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 ~ ------- Andrew C. Lehman, Esquire ~. (;:J f''-,'l CJ ~... RICHARD BOTTORF, JR. and BRENDA BOTTORF, his wife, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. NO. 04-145 Civil Term JENNIFER SHARAR, Defendant JURY TRIAL DEMANDED CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Jennifer Sharar, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. DJ ($/01 Byfv{ucCZk1 Michael S. Ferguson, Esquire I.D. #: 83882 2411 North Front Street Harrisburg,PA 17110 717/232-9900 Date: CERTIFICATE OF SERVICE AND NOW, this It^- day of August, 2004, I hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael E. Kosik, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110 1)u~iZf~ Michael S. Ferguson, Esquire "J C.:;, C,~, --, c,:::: '" t',,, c' r>.,,) . J ~ ANGINO & ROVNER, P.C. Michael E. Kosik, Esquire Attorney ID# : 36513 4503 North Front Street Harrisburg, P A 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosikanino-rovner.com RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A NO. 04-145 CIVIL TERM v. JENNIFER SHARAR Defendant CIVIL ACTION - LAW MOTOR VEHICLE ACCIDENT ACTION JURY TRIAL DEMANDED PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Michael E. Kosik, counsel for the plaintiff in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is up to $25,000. The following attorneys are interested in the case( s) as counselor are otherwise disqualified to sit as arbitrators: Michael E. Kosik, Esquire, Angino & Rovner, P.C., 4503 N. Front St., Hbg, PA 17110 Michael Ferguson, Esquire, Nealon & Gover, P.C., 2411 N. Front St., Hbg., PA 17110. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ichael E. Kosik, Esquire I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff(s) Date: 7/13/06 330442 ;Z:;~19. ~i~ " f' ~ ~ ~ F t{,~ G' J:- --1 rei r -:.--: -,,-... _0 , r .r~ t. II .-; 'I' ' o.'1~ 'J. ANGINO & ROVNER, P.c. Michael E. Kosik, Esquire Attomey ID#: 36513 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238~791 FAX (717) 238-5610 Attomeys for Plaintift{s) -mail: mkoik.no-rovn r. m RICHARD BOTTORF, JR. AND BRENDA BOTTORF, His Wife Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 04-145 CIVIL TERM v. JENNIFER SHARAR Defendant CIVIL ACTION - LAW MOTOR VEHICLE ACCIDENT ACTION JURY TRIAL DEMANDED ORDER OF COURT AND NOW'-11~"8 1'1. 20?06, in considerati?n of the foregoing petition, . ,ESq.,~ t.~Sq.,and sq., are appointed arbitrators in the above-captioned action (or actions) as prayed for. 330442 :ilil 6' .... ~\ i;t - \- {)~ t. I Oi'J1Z ('I"' ,,~ !!' L :h, . (,:,1 ...,.. ,,,0 _ I RICHARD BOTTORF, JR. AND BRENDA BOTTORF, his wife, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. JENNIFER SHARAR, DEFENDANT 04-0145 CIVIL TERM AND NOW, this ORDER OF COURT I 7 f'iI\ day of October, 2006, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED and Charles H. Stone, Esquire, Chairman, shall be paid the sum of $50.00. &",-- ,~~?':...y':!~ ~ BY"the Court, L', .~...'. . ~__~".,r-'''.''' . f Edgar B. Bayley. J. Charles H. Stone, Esquire Court Administrator :sal f t"/ ~, ~ o ?i 0 4. .. '0 :::: ~~ ~ ~t ~ r;:~ ~ u... ~ o c-a fi 3~ I"'~ ;:)3 '~S~~ lJ::. i"J. .' ~ (.) ANGINO & ROVNER, p.e. Michael E. Kosik, Esquire Attorney 10#: 36513 4503 North Front Street Harrisburg, P A 17 \1 0-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: mkosik@angino-rovner.com : IN THE COURT OF COMON PLEAS OF : CUMBERLAND COUNTY, PENNA. RICHARD BOTIORF, JR. AND BRENDA BOTIORF, His Wife Plaintiffs v. : CNIL ACTION - LAW : NO. 04-145 CNIL TERM JENNIFER SHARAR Defendant : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned action as settled, satisfied, and discontinued. Michael E. Kosik, Esquire J.D. No. 36513 4503 N. Front Street Harrisburg, P A 17110 (717) 238-6791 Counsel for Plaintiff DATED: cc: Jenni Herney Allen, Esquire 341751 68991/LRJ ,.,...., = = e,-' . -. :!J, f') 5=J :D .< N c.n