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Home My WebLink About04-0473ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER ANNE WALTZ, Plaintiff V. DAVID A. DECRENY, JR. Defendant 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. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 _AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan m~s adelante en las siguientes pfiginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despu~s de la notificaci6n 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 aqul en contra suya. Se le advierte de que si usted falla de tomar acci6n 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 reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mils 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 OFIC1NA LE PUEDA PROVEER 1NFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 240434.1 ~RAS\S SA 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER ANNE WALTZ, Plaintiff DAVID A. DECRENY, JR. CIVIL ACTION - LAW NO. em- q7,3 Commonwealth of Pennsylvania, who Cumberland County, Pennsylvania. 2. Defendant David A. Decreny, Jr., is a minor and a citizen of the Commonwealth of Pennsylvania, who currently resides at 205 Wood Street, Camp Hill, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or aborn August 19, 2003, at approximately 7:50 p.m., at the intersection of East Penn Drive and Magaro Road, East Permsboro Township, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Jennifer Anne Waltz was operating a 2001 Toyota Echo in a southbound direction on East Penn Drive approaching the intersection with Magaro Road, East Pennsboro Township, Cumberland County, Pennsylvania. Defendant JURY TRIAL DEMANDED COMPLAINT Plaintiff Jennifer Anne Waltz is an adult individual and a citizen of the currently resides at 175 Erford Road, Camp Hill, 5. At that time and place, Defendant David A. Decreny, Jr. was operating a 1997 Volvo Sedan, owned by his father David A. Decreny, Sr., traveling northbound on East Penn Drive, East Pennsboro Township, Cumberland County, Pennsylvania. 6. At that time and place, Defendant David A. Decreny, Jr., failed to yield the right-of- way to oncoming traffic on East Penn Drive and made a left turn directly into the path of travel of Plaintiff Jennifer Anne Waltz's vehicle causing a violent collision to occur. 7. At that time and place, the front portion of Plaintiff Jennifer Anne Waltz's vehicle collided with the right side of Defendant Decreny's vehicle. 8. The foregoing accident and all the injuries and damages set forth hereinafter sustained by Plaintiff Jennifer Anne Waltz are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant David A. Decreny, Jr. operated his motor vehicle as follows: (a) failure to have his vehicle under such control as to be able to stop within the assured clear distance ahead; (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) failure to travel at a safe speed while approaching an intersection; (d) failure to apply his brakes in sufficient time to avoid the colliding with the Plaintiff's vehicle; (e) failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; (f) failure to have proper and adequate control over his vehicle; 240434.1 ~RAS\SSA 2 (g) failure to yield the right-of-way to Plaintiffs vehicle; (h) failure to take reasonable evasive action to avoid the accident; and (i) 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. 9. As a result of the aforementioned accident, Plaintiff Jennifer Anne Waltz sustained painful and severe injuries which include, but are not limited to, sprained left wrist, separated left shoulder, compressed nerve in left thumb, sprained neck and low back strain 10. By reason of the aforesaid injuries sustained by Plaintiff Jennifer Anne Waltz, she was forced to incur liability for medications, hospitalizations, rehabilitation and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 11. Because of the nature of her injuries, Plaintiff Jennifer Anne Waltz has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 12. As a result of the aforementioned collision and resulting injuries, Plaintiff Jennifer Anne Waltz has undergone and in the future will undergo great physical and mental suffering, great inconvenience in can'ying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 13. As a result of the aforementioned collision and resulting injuries, Plaintiff Jennifer Anne Waltz has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 240434. I\RAS\SSA 3 14. As a result of the aforementioned collision and resulting injuries, Plaintiff Jennifer Anne Waltz has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 15. As a result of the aforementioned collision and resulting injuries, Plaintiff Jennifer Anne Waltz has sustained uncompensated work loss, and claim is made therefor. 16. As a result of the aforementioned collision and resulting injuries, Plaintiff Jennifer Anne Waltz 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 therefor. Date: February 3, 2004 WHEREFORE, Plaintiff Jennifer Anne Waltz demand judgment against Defendant David A. Decreny, Jr. in an amount in excess of Twenty-Five Thousand Dollars ($25,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 240434.1 \RAS\SSA 4 VERIFICATION I, Jennifer Clarke Waltz, Plaintiff, have read the foregoing and do hereby swear or affirm that the facts set forth in the foregoing PLAINTIFF'S 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 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. Jel~fer ClUe Waltz Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, L.L.P. 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 (717) 299~1811 - FAX Attorney I.D. No: 55919 Attorney for Defendant JENNIFER ANNE WALTZ, Plaintiff VS. DAVID A. DECRENY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. 04-473 JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant David A. Decreny, Jr., in reference to the above matter. NIKOLAUS & HOHENADEL, LLP / Joseph~.~uzic, Jr., Esquire Attorl~y'2'or Defendant DATE: /~Tt- ~, ,.~ -- O %t~ CERTIFICATE OF SERVICE I hereby certify that a tree and correct copy of the foregoing Entry of Appearance was sent by first-class mail, postage prepaid on the date set forth to the following: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 NIKOLAUS & HOHENADEL, LLP Date: Joseph~. lq~zic, Jr., Esquire Attorfey for Defendant SHERIFF'S RETURN - REGULAR CASE NO: 2004-00473 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WALTZ JENNIFER ANNE VS DECRENY DAVID A JR GERALD WORTHINGTON , Cumberland County, Pennsylvania, says, the within NOTICE DECRENY DAVID A JR DEFENDANT , at 0019:30 HOURS, at 205 WOOD STREET CAMP HILL, PA 17011 DAVID A. DECREN¥, JR. a true and attested copy of NOTICE COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the llth day of February 2004 by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9,66 Affidavit .00 Surcharge 10.00 .00 37.66 Sworn and Subscribed to before me 5his 23~C_ day of J~ ~V A.D. So Answers: 02/12/2004 A/qGINO & ROVNER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WALTZ Vs. : DECRENY JR : NO. 04473 CERTIFICATE PREREQUISITE TO SERV/CE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JOSEPH G MUZIC, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3.No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 03/31/04 JOSEPH G MUZIC, 212 N QUEEN ST ESQUIRE LANCASTER, PA 17603 717-299-3726 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC 4940 DISSTON STREET ' PHILADELPHIA PA 19135 (215) File #: M309009 By: Sandra Venziale IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WALTZ Vs. DECRENY JR No. 04473 TO: RICHARD SADLOCK, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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. Date: 03/10/04 JOSEPH G 5gJZIC, ESQUIRE 212 N QUEEN ST LANCASTER, PA 17603 ATTORNEY FOR DEFENDANT Enc(s): File #: Copy of subpoena(s) Counsel return card M309009 INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215), 335-3336 INC. By: Sandra Venziale C~TH OF PE~VAN/A ODUNTY OF WALTZ : Vs. DECRENY JR : ~ileNo. 04473 SUB~NA TO P~OOC~ DOCt~NTS (19 THINC~ ~0~ D~V~RY P~ TO ~ 4009.~ TO: ~YSTONE RE~ SYSTEMS, 101 ERFO~ RD STE 202, ~P HILL PA 17011 (N~ of P~s~ ~ 5ntity) Within tw~ty (20) days aft~ s~vice of this Sub__ha, y~ ~e ~d~ed by the c~rt to Or~uce the fo]]~ ~tm ~ ~in~s: SEE -AT'rACeD ~DE~D'U~ - MEDICAL LEGAL REPRODUCTiONS~A~0~s~940 DISSTON ST., PHILA., PA You may delive~ o~ mail legible cooies of the docuneots o~ pro.ce thin~s requested b) this sub--a, t~eth~ w~th the certif~te of ~,~li~ce, ~ the p~ty ~king thi~ r~uest at the address ]~st~ ~ve. Y~ have the ri~t to s~k in advice the rea~on~Je cost of oreo~ng the ~es or or~uc~n~ the th~ngs s~ght. ~ y~ fa~] ~ pr~u~ the ~nts ~ th~ngs red,red by ~s s~na w~th~n twenty (20) days after ~ts s~v~, the O~ty s~v~ th~s s~a ~y seek a ~rt orde~- ~,~e]]~ y~ to ~,~]y w4th ~t. THIS SUBPOENA WAS ISSUED AT THE RE(;~.I~ST O~ THE FOLLOWING PERSON: NAMe: JOSEPH' G MUZTC, ESQ 212 ........ TEL EPHONE: SUPRIS~E COURT ID # ATTORNEY FOR: M309009-01 LANCASTE]~17603 215-335-3212 DEFENDANT Seal of th~Court BY THE COURT: Prothonotary/~le~k, Otvi 1 Divisio~ Deputy (Elf. 7/97) WALTZ Vs. DECRENY JR ADDENDUM TO SUBPOENA No. 04473 CUSTODIAN OF RECORDS FOR: KEYSTONE REHAB SYSTEMS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAy REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: JENNIFER ANNE WALTZ ADDRESS: 175 ERFORD RD CAMP HILL PA DATE OF BIRTH: 08/31/79 SSAN: 204602771 A/K/A CLARKE CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NODOCUMENTSAVAiLABLE:i hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Fate CUMBERLAND M309009-01 ~uthorized signature for KEYSTONE REHAB SYSTEMS *** SIGN AND RETURN THIS PAGE *** CO--TH OF P~VAN/A GOONTY OF (~ WALTZ : Vs. : : File No. DECRENY JR : 04473 TO: SUS~K)ENA TO PROOJCE OOOJMENTs O~ ~IN~S F~(19 DISCOVERY PURSUANT TO_RULE 4009.22 DR BALINT BALOG, 875 POPLAR CHURCH RD, CAMP HILL PA 17011 (N~me of Pe~so~ o~ Entity) Within twenty (20) days afte~ service of this subpoena, you a~e o~de~ed by the court to pm:duce the roi lowin9 doc~m~t.~ cc~g~ ._ ___ at MEDICAL LEeAL REPRODUCTiONSfA~s~940 DISSTON ST., PHILA., PA You may de)iYe~ cc mai) legible conies of the doc~ne~ts cc 0roduce things requested tb~s subpoena, to~ethem w~th the c~t~f~te of ~]~ce, to the ~t~ ~k~m~ th~ r~uest at the ad~s ]~st~ ~ve. Y~ ~ave the r~t to s~k ~n advice the rea~o~ cost of ~reO~im~ the ~ies or Dm~uc~m~ the th~m~s s~ht. If y~ fail ~ P~ce the ~ts ~ things re~ired by ~s s~ena within twenty (20) days aft~ its s~v~ce, the p~ty servi~ this s~a ~y seek a ~t ~de~- ~elling Y~ to ~1~ with it. ~IS ~ WAS I~ AT ~ RE~ST~ ~ F~L~i,~ pER~: TELEPHONE: SI. JPREPE ODURT ID # ATTORNEy FOR: JOSEPH~ MTJ~_ZIC, ESQ a ~--~T LARCAS'rEK, FA 17603 215-335-3212 M309009-02 DEFENDANT Sea] of the Oou~t BY TPE ~w 1, Division D~uty (Eff. 7'/97) WALTZ Vs. DECRENY JR ADDENDUM TO SUBPOENA No. 04473 CUSTODIAN OF RECORDS FOR: DR BALINT BALOG ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EX~34INATION OR TREATMENT RENDERED TO: NAME: JENNIFER ANNE WALTZ ADDRESS: 1.75 ERFORD RD CAMP HILL PA DATE OF BIRTH: 08/31/79 SSAN: 204602771 A/K/A CLARKE CERTIFIED PHOTOCOP/ES W/LL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDS AREATTACHEDHERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NODOCUMENTSAVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M309009-02 Authorized signature DR BALINT BALOG for *** SIGN AND RETURN THIS PAGE *** CO~ OF P~YLVANIA WALTZ : VS. : DECRENY JR : 04473 TO: SU~PO~NATOPRODVC~DO~NTSO~THI~: f~ OI~Y ~ TO ~ HOLY SPIRIT HOSP. 503 N 21ST ST, ~P HILL PA 17011 AT~: ~DI~ RECO~S DEPT (N~ of P~s~ ~ Entity) Within twenty (20) days afte~ service of this subpoena, you a~e o~de~ed by the court to Prc~uce the fol lowing ~t.~ o~n.g_~k: ._ --_ at MEDICAL LE~%L REPRODUCTiONSfA~s~940 DISSTON ST., PHILA., PA You may deliv~ oc ~Jl l~ible ~ies of the ~ts ~ price things requested b~ th~s sub--a, togeth~ with the c~tff~cate of ~,~l~ce, to the p~ty ~kin~ th~ me.est at ~e ad.ess l~st~ ~ve. Y~ have the r~t to s~k ~n advice the rea~on~]e cos~~ of pre~ing the ~p~es or pricing the things s~t. If y~ fa~l ~ pr~uce ~e ~nts ~ things re~tr~ by ~is s~ena within twenty (20) days sft~ its smv~m, the p~ty serving tht~ s~ ~y se~ a :rt ~de~- ~elli~ y~ to ~]y with i~. ~lS ~ WAS I~ AT ~ RE.ST ~ ~ F~L~I~ PER~: ~: JOSEPH~ ~Zip' ESQ ~E~: ~~T TELEPHONE: SUPREME OD.~T I D ~ ATTOrNEy FOR: M309009-03 215-335-3212 DEFENDANT DATE:~L~A~ /~ Seal of the Cou~£ BY ~ CO,~T: Prothcx~otar¥/~[~k, Ct¥il Dtvisien Deputy -- (Eff. 7/97) WALTZ Vs. DECRENY JR ADDENDUM TO SUBPOENA No. 04473 CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: JENNIFER ANNE WALTZ ADDRESS: 175 ERFORD RD CAMP HILL PA DATE OF BIRTH: 08/31/79 SSAN: 204602771 A/K/A CLD~RKE ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN COMPLETE AND RETURN [ ] [ ] RECORDS AREATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, Information and belief all documents or things above mentioned have been produced. NODOCUMENTSAVA1LABLE:i hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M309009-03 Authorized signature HOLY SPIRIT HOSP for * * * SIGN AND RETURN THIS PAGE * * * CO~V[]NWEALTH OF P~qNSYLVANIA WALTZ : Vs. : : File No. DECRENY JR : 04473 TO: SUBPOE~NAToPROOI~CE~NTSORTHi~ ~O1~ DISCOVERY PURSUANT TO ~ CAPITAL BLUE CROSS, 2500 ELMERTON AVE #2215 HARRISBURG PA 17110-9956 ATTN: PERSONNEL DEPARTMENT ' (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you a~e ordered by the court to produce the fo1 lowing dOCUl~nt.~ o~o~J.3.~pg§..._ .... ._ at MEDICAL LEGAL REPRODUCTiONS~A~d~ ~ ~s 9%0 DISSTON ST., PBILA., PA You may del~ver or mail legible copies of the docunents o. produce things requested bt this sub~3ena, togethe~ with the certificate of conwliance, to the oa~t¥ making thi~ request at _the add~ess listed above. You have the right to seek in advance the reasonable cost of prepering the copies or producing the things sought. If you fail to produce the doctments or things required by this subpoena within twenty (20) days aften its se~vlce, the pa~ty serving thi.~ sublm3ena may seek a court orde~- ~,~elltn9 you to c.~,~ly with it. THIS SU~NA WAS ISSUED AT THE RE(~$T OF THE FO~LOWIN~ PERSON: NAME: JOSEPH G MUZIC, ESQ TELEPHONE: SUPREME COURT ID # A3-FORNEY FOR: L~NC~%~'~'.:~, WA 17603 215-335-3212 M309009-04 DEFEND2~NT DATE: Seal of the Cou~t BY THE COURT: Pr°th°n°tery/~le~k, Ot¥t] Divis~en Deputy (Elf. 7/97) WALTZ Vs. DECRENY JR ADDEND UM TO SUBPOENA No. 04473 CUSTODIAN OF RECORDS FOR: CAPITAL BLUE CROSS ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANy W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO: NAME: JENNIFER ANNE WALTZ ADDRESS: 175 ERFORD RD CAMP HILL PA DATE 0F BIRTH: 08/31/79 SSAN: 204602771 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE:i hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M309009-04 ~uthorized signature for CAPITAL BLUE CROSS *** SIGN AND RETURN THIS PAGE *** CO~~ OF P~VANIA COONTY OF ~ WALTZ : : Vs. : : F~]e No. DECRENY JR : 04473 TO: SUBPOENA TOPROOUCEDOC~NTSORTHi~%% F--ORDISCOVERYPURSUANTTO_RiJi_E 4009.2? COMMUNITY MED ASSOCS, 3601 N PROGRESS AVE, HARRISBURG PA 17110 (Name of Person or Entity) Within twenty (20) days afte~ service of this subpoena, you a~e ocde~ed by the court to produce the followin9 doc~rnent.~ ors~pg~~___- at MEDICAL LEGAL RZPRODUCTiONS~A~gs~940 DISSTON ST., PHILA., PA You may de]ive~ o~ mmi] legible co~ies of the doc~nemts o~ 0roduce th~ngs requested th~s sUb--a, ~eth~ w~th the c~t~f~te of ~]~e, to the O~ty ~k~ng m~uest at the ad.ess ]~sted ~ve. Y~ have the ~t to s~k ~n advice the ~ea~o~]~ cost of prep~ th~'~es or Pr~uc~n9 the th~ngs s~ght. if you fail ~ pm~uce the ~ts ~ things re~i~ by ~is sub~a within twenty (20) days aft~ its s~v~, the p~ty serving this s~a ~y sc:k a ~rt orde~- ~1~ ~ W~ i~ AT ~ RE.ST ~ ~ F~t~l~ PER~: JOSEPH G ~ZI~, ESQ TELEPHONE: SUPRE/tE COURT ID # ATTORNEY FOR: LANCA~'~'~. FA 17603 215-335-3212 DEFENDANT M309009~05 Seal of the Cou~t - BY ~ CG~NRT: ProtF~t~mry/~le~k, 01¥i 1 Division Deputy (Elf. 7/97) WALTZ Vs. DECRENY JR ADDENDUM TO SUBPOENA No. 04473 CUSTODIAN OF RECORDS FOR: COMMUNITY MED ASSOCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDs AND ANy OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: JENNIFER ANNE WALTZ ADDRESS: 175 ERFORD RD CAMp HILL PA DATE OF BIRTH: 08/31/79 SSAN: 204602771 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentJ, oned have been produced. ] NODOCUMENTSAVAILABLE: I hereby certify that .a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( } RECORDS / XRAYS have been destroyed Date CUMBERLAND M309009-05 ~uthorized signature for COMMUNITY MED ASSOCS *** SIGN AND RETURN THIS PAGE *** IN THE COURT OF COMMON PEEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JENNIFER ANNE WALTZ, Plaintiff DAVID A. DECRENY, JR. Defendant TO THE PROTHONOTARY: CIVIL ACTION - LAW NO. 04-473 Civil JURY TRIAL DEMANDED PRAECIPE Please mark the above-captioned action as settled, satisfied, and discontinued. ANGINO Date: September 2, 2004 Esquire I.D. No. 47281 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6'791 Counsel for Plaintiffs .CERTIFICATE OF SERVICE I, Marcy L. Brymesser, 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 PI~kECIPE on the following via postage prepaid, first class United States mail, addressed as follows: Joseph G. Muzic, Esquire Nikolaus & Hohenadel, LLP 212 North Queen Street Lancaster, PA 17603 Date: September 2, 2004 283212