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HomeMy WebLinkAbout08-1162ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com KATHY STEPHENS and MARK STEPHENS, Plaintiffs V. ROBERT BULLOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 68- 11(0A 0,1vil 1&-M CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. ORIGINAL 350262 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KATHY STEPHENS AND MARK STEPHENS TERM, CUMBERLAND -VS- CASE NO: 08-1162 ROBERT BULLOCK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 05/20/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.61 118-H DE11-0752564 74415-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NEUROLOGY CENTER HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL BOWMANSDALE FAMILY PRACTICE JOSEPH A. CINCOTTA, MD. ORTHOPEDIC INSTITUTE OF PA. HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact R1.50S 116-H MCS on behalf of ¦ STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0392339 74415-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS File No. 08-1162 VS. ROBERT BULLOCK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NEUROLOGY CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: _ **** SEE ATTAC FD MF.R **** at The MCS 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: STEPHEN L BANKO JR ESO ADDRESS: 3510 TRINDLF ROATD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAY 2 0 2008 Date: 41408 Seal of the Court BY THE C rT. 40 Prothonotary/C '4Diion Deputy 74415-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NEUROLOGY CENTER 897 POPLAR CHURCH ROAD CARLISLE, PA 17011 RE: 74415 KATHY STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : KATHY STEPHENS 1754 SOUTH YORK STREET, MECHANICSBURG, PA 17055 Social Security #: XXX-XX-8279 Date of Birth: 02-27-1959 R1.50S 116-H SU10-0732200 74415-LO1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -vs- ROBERT BULLOCK OR Nlil COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-1162 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 05/20/2008 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.61 118-H DE11-0752565 74415-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NEUROLOGY CENTER HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL BOWMANSDALE FAMILY PRACTICE JOSEPH A. CINCOTTA, MD. ORTHOPEDIC INSTITUTE OF PA. HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact R1.50S 116-H MCS on behalf of STEPHEN L. BANKO, JR., ESQ. I Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 D902-0392339 74415-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS VS. ROBERT BULLOCK File No. 08-1162 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 RIDIFE **** at The MCS Group- Inc.- 1601 Market Street, Suite 800. Phil delphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAY 2 0 2008 Date: J a21f?08 Seal of the Court BY THE URT: Proth otary/C vil D"ton Deputy 74415-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL MEDICAL RECORDS 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 74415 KATHY STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurses notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : KATHY STEPHENS 1754 SOUTH YORK STREET, NECHANICSBURO, PA 17055 Social Security #: 208-52-8279 Date of Birth: 02-27-1959 R1.50S 116-H SU10-0732202 74415-LO2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 OIN THE MATTER OF: COURT OF COMMON PLEAS KATHY STEPHENS AND MARK STEPHENS TERM, CUMBERLAND -VS- CASE NO: 08-1162 ROBERT BULLOCK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 05/20/2008 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.61 118-H DE11-0752566 74415-L03 COMMONWEALTH OF PENNSYLVANIA COUN'T'Y OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK ¦ COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCDIEENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NEUROLOGY CENTER HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL BOWMANSDALE FAMILY PRACTICE JOSEPH A. CINCOTTA, MD. ORTHOPEDIC INSTITUTE OF PA. HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO JR. ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2008 MCS on behalf of CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact 21.505 116-H STEPHEN L. BANKO, JR., ESQ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DB02-0392339 74415-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS File No. 08-1162 VS. ROBERT BULLOCK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRiSB TR HO 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: **** SEE ATTACHED RIDER **** at The MCS Cm=_ Inc 1601 Market Street Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO. JR ESQ ADDRESS: 3510 TRINDLE ROAD CAMP HILL.. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAY 2 0 2008 Date: Seal of the Court BY THE CO T: Prothon tary/C1?i 7on Deputy 7dd I S l EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG. PA 17101 RE: 74415 KATHY STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurses notes, doctors comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : KATHY STEPHENS 1754 SOUTH YORK STREET, MECHANICSBURO, PA 17055 Social Security #: 208-52-8279 Date of Birth: 02-27-1959 R1.50S 116-H SU10-0732204 74415 -L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA ? 's .r PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KATHY STEPHENS AND MARK STEPHENS TERM, CUMBERLAND -VS- CASE NO: 08-1162 ROBERT BULLOCK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22,- MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 05/20/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.61 118-H DE11-0752567 74415-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCONENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NEUROLOGY CENTER HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL BOWMANSDALE FAMILY PRACTICE JOSEPH A. CINCOTTA, MD. ORTHOPEDIC INSTITUTE OF PA. HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact R1.50S 116-H MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 D802-0392339 74415-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS VS. ROBERT BULLOCK File No. 08-1162 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BOWMANSDAL.E FAMILY 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 ATTACHED RIDER **** at The MCS Goo- Inc-- 1601 Market Street. Suite 800- Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: _ STEPHEN L. BANKO. JR.. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL- PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAY 0 2008 Date: y a 8 Seal of the Court BY THE COURT. Pr ono Ci p ivision Deputy 74415-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BOWMANSDALE FAMILY PRACTICE 1 KACEY COURT SUITE 101 MECHANICSBURG, PA 17055 RE: 74415 KATHY STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : KATHY STEPHENS 1754 SOUTH YORK STREET, MECHANICSBURG, PA 17055 Social Security #: BEE-BB-8279 Date of Birth: 02-27-1959 R1.50S 116-H SU10-0732206 74415-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KATHY STEPHENS AND MARK STEPHENS TERM, CUMBERLAND -VS- CASE NO: 08-1162 ROBERT BULLOCK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 05/20/2008 MCS on behalf of STEPHEN L. BANKO, JR.- ,-Attorney for DEFENDANT R1.61 118-H DE11-0752568 74415-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUJMTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NEUROLOGY CENTER MEDICAL RECORDS HOLY SPIRIT HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL MEDICAL RECORDS BOWMANSDALE FAMILY PRACTICE MEDICAL RECORDS JOSEPH A. CINCOTTA, MD. MEDICAL RECORDS ORTHOPEDIC INSTITUTE OF PA. MEDICAL RECORDS HERSHEY MEDICAL CENTER MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2008 MCS on behalf of CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact R1.50S 116-H STEPHEN L. BANKO, JR., ESQ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0392339 74415-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS File No. 08-1162 VS. ROBERT BULLOCK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOSEPH A. CINCOTTA_ MD. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The M CS ff= Inc-- 1601 Market Stree Suite 800 p it delnh+'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 comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L BANKO JR ESO ADDRESS: 3510 TRINDLE ROAD _CAM_P HILL.. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: le- Pro onotary/Cl lvil D' 'sion MAY 2 ©2008 Date: Deputy Seal of the Court 7dd1 5115 ¦ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOSEPH A. CINCOTTA, MD. 2140 FISHER ROAD MECHANICSBURG, PA 17055 RE: 74415 KATHY STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : KATHY STEPHENS 1754 SOUTH YORK STREET, MECHANICSBURG, PA 17055 Social Security 8: XXX-EE-8279 Date of Birth: 02-27-1959 R1.50S 116-H SU10-07322o8 74415-LO5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS KATHY STEPHENS AND MARK STEPHENS TERM, CUMBERLAND -VS- CASE NO: 08-1162 ROBERT BULLOCK As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 05/20/2008 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.61 118-H DE11-0752569 74415-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NEUROLOGY CENTER HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL BOWMANSDALE FAMILY PRACTICE JOSEPH A. CINCOTTA, MD. ORTHOPEDIC INSTITUTE OF PA. HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact R1.50S 116-H MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 D1302-0392339 74415-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS File No. 08-1162 VS. ROBERT BULLOCK 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 ATTACHED RIDER **** at The MCS a= Inc- 1601 Market Street Suite 800 P iladelnhia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAY 2 0 2008 Date: #a qjo8 Seal of the Court BY THE URT: Pro notary/C ivil ivision Deputy 74415-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA. 3399 TRINDLE RD CAMP HILL, PA 17011 RE: 74415 KATHY STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : KATHY STEPHENS 1754 SOUTH YORK STREET, MECHANICSBURG, PA 17055 Social security #: XXX-XX-8279 Date of Birth: 02-27-1959 R1.50S 116-H SU10-073221o 74415-LO6 F7-- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-1162 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22'. MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 05/20/2008 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.61 118-H DE11-0752570 74415-L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 NEUROLOGY CENTER HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL BOWMANSDALE FAMILY PRACTICE JOSEPH A. CINCOTTA, MD. ORTHOPEDIC INSTITUTE OF PA. HERSHEY MEDICAL CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of STEPHEN L. BANKO, JR., ESQ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/30/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact MCS on behalf of STEPHEN L. BANKO, JR., ESQ. I Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS File No. 08-1162 VS. ROBERT BULLOCK SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HFRSHRY MFr?rr• e r 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: **** S ATTACHFn ?mER **** at The MCS Gmijp Inc 1 I L- 601 Il1Vket t Quite 800 P1LlaadelnMa- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L B NKO ESO ADDRESS: 3510 TRpfl)LF u s e r, CAMP HII.i • PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAY 2 0 2008 Date: I y/4 BY THE URT: Proth otary/Cler 'sion Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER MEDICAL RECORDS 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 74415 KATHY STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurses notes, doctors comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : KATHY STEPHENS 1754 SOUTH YORK STREET, MECHANICSBURG, PA 17055 Social Security #: 208-52-8279 Date of Birth: 02-27-1959 R1.50S 116-H SU10-0732212 74415-L07 C1 - (7 ...i V ID I q 0 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford St., Carlisle, PA 17013 TELEPHONE 717-249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mas adelante en las siguientes piginas, debe tomar accion dentro de los proximos veinte (20) dias despuds de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a , las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes Para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford St., Carlisle, PA 17013 TELEFONO 717-249-3166 350262 ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com KATHY STEPHENS and MARK STEPHENS, Plaintiffs V. ROBERT BULLOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 0 k- ?'- CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Kathy and Mark Stephens are adult individuals and citizens of the Commonwealth of Pennsylvania who resides in Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Robert Bullock is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 119 Hill Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. The facts and occurrences hereinafter related took place on or about April 5, 2006, at approximately 7:00 p.m. at the intersection of Silver Spring Road and the Carlisle Pike, Cumberland County, Pennsylvania. 4. At that time and place, Kathy Stephens was operating a 1998 Honda Accord and was traveling north on the Carlisle Pike through a green light at the intersection of Silver Spring Road and the Carlisle Pike. 5. At the same time, Defendant Robert Bullock was operating a 2000 Oldsmobile Silhouette minivan and was traveling south on the Carlisle Pike. 350262 6. Defendant Robert Bullock failed to yield to oncoming traffic and started to turn left across the Carlisle Pike onto Silver Spring Road. 7. Defendant Robert Bullock did not have the right-of-way. 8. Defendant Robert Bullock turned left in front of Kathy Stephen's oncoming vehicle, and she hit the side of his vehicle. 9. Defendant Robert Bullock's vehicle was pushed through the intersection into Paige Faulk's 2000 Chevrolet while she waited at the red light on Silver Spring Road. 10. The foregoing accident and all of the injuries and damages set forth herein sustained by Plaintiffs Kathy and Mark Stephens are the direct and proximate result of the negligent, careless, wanton, and reckless manner in which Defendant Robert Bullock operated his motor vehicle as follows: a. failure to keep alert and maintain a proper watch for the presence of other motor vehicles upon the highway; b. failure to yield to oncoming traffic; C. failure to obey posted traffic signals; d. failure to travel at a safe speed; e. driving his 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. 350262 2 CLAIM I Kathy Stephens v. Robert Bullock 11. Paragraphs 1 through 10 of the Complaint are incorporated herein by reference. 12. Plaintiff Kathy Stephens sustained painful and severe injuries which include but are not limited to, a right hip injury; head pain; neck pain; lower back pain; a left wrist injury; and bruising on her knees, arms, legs, and hip. 13. By reason of the aforesaid injuries sustained by Plaintiff Kathy Stephens, she was forced to incur liability for medical treatment in an effort to restore herself to health, and claim is made therefor. 14. Because of the nature of her injuries, Plaintiff Kathy Stephens has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 15. As a result of the aforementioned injuries, Plaintiff Kathy Stephens has undergone and in the future may undergo physical and mental suffering, inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 16. As a result of the aforementioned injuries, Plaintiff Kathy Stephens has been and in the future may be subject to humiliation and embarrassment, and claim is made therefor. 17. Plaintiff Kathy Stephens continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefore. 350262 3 CLAIM II Mark Stephens v Robert Bullock 18. Paragraphs 1 through 17 of the Complaint are incorporated herein by reference. 19. As a result of the aforementioned injuries sustained by his wife, Plaintiff Mark Stephens has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which will be to his great detriment, and claim is made therefor. WHEREFORE, Plaintiffs Kathy and Mark Stephens demand judgment against Defendant Robert Bullock in an amount in excess of Fifty Thousand Dollars ($50,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINO & ROVNER, P.C. Dater 2?t7 David L. Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 -phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiffs 350262 4 VERIFICATION We, Kathy Stephens and Mark Stephens, Plaintiffs, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of our knowledge, information and belief. We understand that this Verification is made subject to the penalties of 18 Pa. Cons. Stat. Ann. §4904, relating to unworn falsification to authorities. Dated: ! ?? U 350262 Mar Step WITNESS: 9-5 ? # c.xa C31 W b O SHERIFF'S RETURN - REGULAR CASE NO: 2008-01162 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STEPHENS KATHY ET AL VS BULLOCK ROBERT RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the DEFENDANT , at 1520:00 HOURS, on the 7th day of March , 2008 at 119 HILL LANE MECHANICSBURG, PA 17050 by handing to HELEN BULLOCK, SPOUSE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.52 Postage .58 Surcharge 10.00 .00 /i?IQS' ? 40.10 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 03/10/2008 ANGINO & ROVNER By: Deputy Sheriff A. D. 4 M6 STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 E-mail: sbanko(&margolisedelstein.com Attorney for Defendant Robert Bullock KATHY STEPHENS and MARK STEPHENS, Plaintiffs V. ROBERT BULLOCK, Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1162 JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Kindly enter my appearance on behalf of Defendant, Robert Bullock, in the above-captioned matter. MARGOLIS EDELSTEIN Date: , By: At k SSTMflft L BANKO, JR Robert Bullock J ? i CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing on all counsel of record by placing the same in 1the United States mail at Camp Hill, Pennsylvania, first- class postage prepaid, on the J qyh day of 1"600k 11 , 2008 and addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 Attorney for Plaintiff Angela M. Gayman, Secret ry 2 C> ?R STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 E-mail: sbanko(a)marxolisedelstein.com Attorney for Defendant Robert Bullock KATHY STEPHENS and MARK STEPHENS, Plaintiffs V. ROBERT BULLOCK, Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1162 JURY TRIAL DEMANDED NOTICE TO PLEAD TO: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 Attorney for Plaintiff You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. MARGOLIS EDELSTEIN Date: ?T a By: ST N . BANKO, JR Attorney for Defendant, Robert Bullock STEPHEN L. BANKO, JR., ESQUIRE Pa. Supreme Court I. D. No. 41727 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 FAX: (717) 975-8124 E-mail: sbanko(&margolisedelstein.com Attorney for Defendant Robert Bullock KATHY STEPHENS and MARK STEPHENS, Plaintiffs V. ROBERT BULLOCK, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1162 JURY TRIAL DEMANDED Defendant ANSWER AND NEW MATTER OF DEFENDANT, ROBERT BULLOCK, TO PLAINTIFFS' COMPLAINT 1. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Denied as stated. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. 7. Denied as stated. The allegations contained in this paragraph state a legal conclusion to which no response is necessary. 2 8. Admitted in part and denied in part. While it is admitted that there was an impact between the vehicles operated by Defendant and Plaintiff-Wife, the Answers contained in paragraphs 6 and 7 hereof are incorporated herein by reference as if set forth in its entirety. 9. Admitted. 10a-e. The Answer contained in paragraph 6 hereof is incorporated herein by reference as if set forth in its entirety. By way of further Answer, with regard to any allegation concerning Plaintiffs' alleged injuries, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of said averments and, therefore, they are denied. CLAIM I Kathy Stephens v. Robert Bullock 11. The Answers contained in paragraphs 1 through 10 hereof are incorporated herein by reference as if set forth in its entirety. 12. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 13. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 14. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 3 t 15. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 16. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. 17. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. CLAIM II Mark Stephens v. Robert Bullock 18. The Answers contained in paragraphs 1 through 17 hereof are incorporated herein by reference as if set forth in its entirety. 19. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph and, therefore, they are denied. WHEREFORE, Defendant, Robert Bullock, demands judgment in his favor and against Plaintiffs. NEW MATTER 20. The Answers contained in paragraphs 1 through 19 hereof are incorporated herein by reference as if set forth in its entirety. 21. Plaintiffs' claims, if any, are subject to and governed by their tort selection under the Pennsylvania Motor Vehicle Financial Responsibility Law. 4 Date: 0 MARGOLIS EDELSTEIN By: 4L. BANKO, JR Attorney for Defendant, Robert Bullock VERIFICATION I, Robert Bullock, have read the foregoing Answer and New Matter to Plaintiffs' Complaint. The factual statements contained therein are known by me and are true and correct to the best of my knowledge, information and belief. This statement and verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsifications to authorities, which provides that, if I knowingly make false averments, I may be subject to criminal penalties. Date: COY ??-? Robert Bullock CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first- class postage prepaid, on the 5* day of hdnC_:w , 2008 and addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 Attorney for Plaintiff ",.Actmmu?j Angela M. Gayman, cretary 6 'Tl f f s ?'? ' ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com KATHY STEPHENS and MARK STEPHENS, Plaintiffs V. ROBERT BULLOCK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-1162 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFFS' REOUEST FOR ADMISSIONS TO DEFENDANT - SET NO.1 To: Defendant Robert Bullock, by and through counsel Stephen L. Banko Jr., Esquire Please take notice that you are hereby required, pursuant to Rule 4014 of the Pennsylvania Rules of Civil Procedure (Federal Rules of Civil Procedure 36), to serve upon the undersigned within thirty (30) days from service, your response to the admission(s) requested herein: 1. Do you admit that you were involved in a motor vehicle collision on April 5, 2006, at approximately 7:00 p.m. at the intersection of Silver Spring Road and the Carlisle Pike? Admit Deny 381911 1 2. Do you admit that before the subject motor vehicle collision, you were operating a 2000 Oldsmobile Silhouette mini-van, traveling south on the Carlisle Pike? Admit Deny 3. Do you admit that it was your intention to turn left from the Carlisle Pike onto Silver Spring Road? Admit Deny 4. Do you admit that as you turned left, your vehicle was struck by a 1998 Honda Accord that had been traveling north on the Carlisle Pike? Admit Deny Date: April 11 , 2008 ANGINO & ROVNER, P.C. L. Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 -phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiffs 381911 2 CERTIFICATE OF SERVICE I, Kathy A. Toney, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PLAINTIFFS' REQUEST FOR ADMISSIONS - SET 1 upon all counsel of record via postage prepaid first class United States mail addressed as follows: Stephen L. Banko Jr., Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Attorney for Defendant athy A. T ney Dated: April _L(, 2008 391911 3 C ?' ? ? ? %'" s? a z.3 ? ? " ?. , q,? •_.,. ? .:::. "S i ,? -?Z .? £ J' "G. " ..w ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attomey ID# : 35956 4503 ;Forth Front Street Harrisburg, PA 17110-1 708 (717) 238-6791 FAX (717) 238-5610 Attomeys for Plaintiff(s) E-mail: dlutz@angino-ro vner.com KATHY STEPHE S and MARK IN THE COURT OF COMMON PLEAS STEPHENS, CUMBERLAND COUNTY, PA Plaintiffs NO. 08-1162 CIVIL TERM V. CIVIL ACTION - LAW ROBERT BULLO K, Defendant JURY TRIAL DEMANDED To: Defendant Stephen L. Please take Rules of Civil Prc within thirty (30) d. 9 )ert Bullock, by and through counsel iko Jr., Esquire :ice that you are hereby required, pursuant to Rule 4014 of the Pennsylvania lure (Federal Rules of Civil Procedure 36), to serve upon the undersigned from service, your response to the admission(s) requested herein: 382808 4 1. Do !you it that before the April 5, 2006, motor vehicle collision, you were planning to turn le from the southbound lane of the Carlisle Pike onto Silver Spring Road and that before initiating yo turn, you had come to a stop? Deny 2. Do ou admit that when you started to make your left turn from the Carlisle Pike, a "green arrow" was of displayed on the traffic signal? Admit Deny 3. Do was going to stop.' admit that after the subject motor vehicle collision, you stated "I thought she Deny ANGINO & ROVNER, P.C Date: David L. Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 - phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiffs 382808 CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am 's day serving a true and correct copy of the PLAINTIFFS' REQUEST FOR ADMISSIONS - S T NO.2 upon all counsel of record via postage prepaid first class United States mail addressed as Stephen L. Banko Jr., Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 Attorney for Defen ant Dated: 382808 C-.+ n.,a `? C-?? c ? C:? ee-? `?T? _ ?? _A r7 __. G _?' ?) ? ,, • . ?L7 ^,°. ..,C so CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-1162 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 06/24/2008 STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT R1.59S 116-H DE11-0758683 77603-LO1 AW 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KATHY STEPHENS AND MARK STEPHENS -VS- ROBERT BULLOCK COURT OF COMMON PLEAS TERM, CASE NO: 08-1162 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ERIE INSURANCE GROUP INSURANCE TO: DAVID L. LUTZ, ESQ., PLAINTIFF COUNSEL MCS on behalf.of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the'twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/04/2008 CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00069 Any questions regarding this matter, contact DAVID L. LUTZ, ESQ. 4503 N. FRONT ST. HARRISBURG, PA 17110 MCS on behalf of STEPHEN L. BANKO, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.59S 116-H D902-0395237 77603 -CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY STEPHENS AND MARK STEPHENS VS. ROBERT BULLOCK File No. 08-1162 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ERIE INSURANCE GROUP (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS C'k=- Inc.. 1601 Market Street. Site 800. Philade hia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: STEPHEN L. BANKO. JR.. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE:. (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY T17 COURT: Prothonotary t?ivi ivision 4, 4/0$ Deputy Date: Seal of the Court 77603-01 ' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ERIE INSURANCE GROUP P.O. BOX 2013 MECHANICSBURG. PA 17055 RE: 77603 KATHLEEN D. STEPHENS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. POLICY #Q102503277; ALL RECORDS SUBMITTED BY OR ON BEHALF OF MS. STEPHENS FOR ANY MVA DURING WHICH SHE WAS INSURED UNDER ANY PRIVATE PASSENGER AUTOMOBILE INS. POLICY ISSUED BY ANY INS. CO. AFFILIATED W/ EIRE INS. GRP. INCLUDING PROPERTY DAMAGE, UIM BENEFITS OR LIABILITY Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiffs claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : KATHLEEN D. STEPHENS 1754 SOUTH YORK STREET, MECHANICSBURG, PA 17055 Social Security.#: XXX-XX-8279 Date of Birth: 02-27-1959 Date of Loss: 04/05/2006 R1.59S 116-H SU10-0737158 77603-LO1 c _. ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com KATHY STEPHENS and MARK STEPHENS, Plaintiffs V. ROBERT BULLOCK, Defendant To the Prothonotary of Cumberland County: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-1162 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE Please mark the above-captioned action settled, satisfied, and discontinued. ANGINO & ROVNER, P.C. David L. Lutz I.D. No. 35956 Date: 377748 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 -phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiff 001&\NNV- JA, CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PRAECIPE upon all counsel of record via postage prepaid first class United States mail addressed as follows: Stephen L. Banko Jr., Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Attorney for Defendant _ ?^n l U?j ?J! Mary T. Geraets Dated: 1 ?- , ( K, G I 377748 :_ . car : ?, ::,;? .:r. i t'?'f > ? 1 ' ?f , p t::} _.,''s 4':;;' .