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HomeMy WebLinkAbout08-3522IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. LARRY M. KRICHMAR and d8- 35a? l??yit -rer K Civil Action -XkX) Law TINA L. KRICHMAR, :iusband and wife ( ) Equity 627 Avery Drive Sugar Land, TX 77479 Plaintiff(s) 8 Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Defendant(s) & Address(es) Please issue writ of summons in the above-captioned action. Xx X Writ of Summons shall be issued and forwarded to ( )Attorney pK)OSheriff Herschel Lock, Esq. dl'l 3107 N. Front Street /l Harrisburg. PA 17110 Signature of Attorney Names/Address/ Telephon No. of Attorney . Supreme Court ID No. 22691 Date: June 2008 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. P othonot Date:- 6111108 by T Deputy ( ) Check here if reverse is issued for additional information CHARITY E. LICHTENBERGER and ANDREW M. LICHTENBERGER 484 Shed Road Newville, PA 17241 versus PROTHON. - 55 SL o 0 O V sU ? v 2 ?Z Vpp, d?f b c? eta n) RIFF'S RETURN - REGULAR CASE NO: 2008-03522 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KRICHMAR LARRY M ET AL VS LICHTENBERGER CHARITY E ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Penns lvania, who being duly sworn according to law, says, the within WRIT O SUMMONS was served upon LICHTENBERGER ANDREW M the DEFENDANT , at 1851:00 HOURS, on the 1st day of July 2008 at 484 SHED ROAD NEWVILLE, PA 17241 ANDREW LICHTENBERGER a true and attested copy of WRIT OF SUMMONS together with and at the same time d4ecting His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 2.00 Affidavit 00 Surcharge 0.00 7'0110f (?-, 00 8- 0 0 Sworn and Subscibed to before me this ay of by handing to So Answers: R. Thomas Kline 07/02/2008 HERSCHEL LOCK By A. D. •N CASE NO: 2008-03522 P COMMONWEALTH OF PENNSYL COUNTY OF CUMBERLAND KRICHMAR LARRY M ET AL IA: VS LICHTENBERGER CHARITY E ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Penns lvania, who being duly sworn according to law, says, the within WRIT O SUMMONS was served upon T,TrWTRNTPR.RC?'RR rWARTTV F the DEFENDANT , at 1555:00 HOURS, on the 26th day of June 2008 at 484 SHED ROAD NEWVILLE, PA 17241 by handing to CHARITY E LICHTENBERGER a true and attested cop* of WRIT OF SUMMONS together with and at the same time dikecting Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge 7Joq)0% So Answers: 8.00 2.00 ?rs+?i%?? .59 ? 0.00 R. Thomas Kline .00 0.59 07/02/2008 HERSCHEL LOCK Sworn and Subscibed to before me this ay of By: ty A. D. SHERIFF'S RETURN - REGULAR it REILLY, JANICZEK & MCDEVITT, P.C. BY: LEE J. JANICZEK, ESQUIRE IDENTIFICATION NO. 68433 SUITE 410 ONE SOUTH PENN SQUARE PHILADELPHIA, PENNSYLVANIA 19107 (215) 972-5200 LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LICHTENBERGER AND ANDREW M. LICHTENBERGER ATTORNEY FOR DEFENDANTS, CHARITY E. LICHTENBERGER AND ANDREW M. LICHTENBERGER COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW JURY DEMAND NO.: 08 - 3522 CIVIL TERM PRAECIPE TO ENTER AN APPEARANCE AND PERFECT A JURY TRIAL TO THE PROTHONOTARY: Please allow this to serve as Defendants formal Praecipe to Perfect a Jury Trial as required under the Pennsylvania Rule of Civil Procedure 1007.1 and Enter our Appearance in the above captioned matter. Respectfully Submitted, REILLY, JANICZEK & MCDEVITT, P.C. By: , Lee iczek, Esquire Attorney for Defendants Date: ? 07 co f ?. sZ? w REILLY, JANICZEK & MCDEVITT, P.C. BY: LEE J. JANICZEK, ESQUIRE IDENTIFICATION NO. 68433 WIDENER BUILDING, SUITE 410 ONE SOUTH PENN SQUARE PHILADELPHIA, PENNSYLVANIA 19107 (215) 972-5200 ATTORNEY FOR DEFENDANT, CHAIRTY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. KITCHENBERGER c`a r CUMBERLAND CO's' .. c37 a Y Q NO. #08-3522 JURY TRIAL DEMDED un Ut CERTIFICATE OF PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER, 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 (20) 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 attached to the notice of intent, is attached to the 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 Provider: Orthopedic Institute of Pennsylvania, Attn: Records Custodian REILLY, JANICZEK & MCDEVITT, P.C. By: Lee niczek, Esquire Date: October 13, 2008 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LARRY M. KRICHMAR AND TINA L. KRICHMAII, h/w PLAINTIFFS 08-3522 File No. VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER ; DEFENDANTS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Orpftedic Institute of Pennsylvania, 3399 Trindle Road, Camp Hill, PA 17011, Attn: Records Custodian (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: Any and all information with respect to any illness, medical history, consultations, prescriptions, an films, slides, reports, bills, billing statements, etc., on behalf of Barbara Edwards, DOB 08/11/1955, SS # 190-44-7075. Reilly Janiczek & McDevitt, P.C., The Widener Bldg.,1 S. Penn Sq., Ste. 410, Phila., PA 19107 at (Address) 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: NAI,&e J. Janiczek, Esquire ADDS 1 s. Tenn aq., rnua., rA lyiu i TELEPHONE: 5200 -- SUPREME COURT ID ?€? ATTORNEY 1433 Defendants, Charity E. LitchenbergerIiE COURT: Andrew M. Litchenberger Date: Prothonotary, Civil Division 'Seal of the Court Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3522 CIVIT TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Orthopedic Institute of Pennsylvania 3399 Trindle Road Camp Hill, PA 17011 Attn: Records Custodian To: Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 Reilly, Janiczek & McDevitt on behalf of Defendants, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER, intends to serve a subpoena identical to the one that is attached to this notice. Please note that you have twenty (20) days from the date listed below within which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty (20) day notice period is waived or if no objection is made, then the subpoena may be served. REILLY, JANICZEK & McDEVITT, P.C. By: ` Lee J. iczek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M. Litchenberger Date: AuEust 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W No.: 08-3522 VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER HIPAA COMPLIANT STATEMENT PURSUANT TO 45 CFR 164.512, °NOTICE" To: Orthopedic Institute of Pennsylvania, Attn: Records Custodian Notice of the attached request for protected medical information was given to the Plaintiff's Attorney in the above-captioned case, who is authorized to accept all legal notices to the Plaintiff in this matter. See attached Notice of Intent to Serve Subpoena. The Notice of Intent to serve subpoena specifically references the protected health information sought, the time for objection has elapsed, and no objections were filed or the objections were waived. See attached Notice of Intent to Serve Subpoena. Thank you for your prompt attention to this matter. REILLY, JANICZEK & McDEVITT, P.C. By: L Lee J. J i ek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M. Litchenberger Date: August 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER No.: 08-3522 REQUEST TO WAIVE 20 DAY NOTICE PERIOD PROVIDED IN RULES 4009.21 AND 4009.22 Custodians: Orthopedic Institute of Pennsylvania 3399 Trindle Road Camp Hill, PA 17011 Attn: Records Custodian Counsel Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 I agree to waive 20 day notice period: Signature Date: r?a ? -? - -c: - ?; ? ? ;? `,=., ?.ti ?1 + l_ ? _ ? ?? ? ? ?? REILLY, JANICZEK & MCDEVITT, P.C. BY: LEE J. JANICZEK, ESQUIRE IDENTIFICATION NO. 68433 WIDENER BUILDING, SUITE 410 ONE SOUTH PENN SQUARE PHILADELPHIA, PENNSYLVANIA 19107 (215) 972-5200 ATTORNEY FOR DEFENDANT, CHAIRTY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. KITCHENBERGER CUMBERLAND COUNTY NO. #08-3522 JURY TRIAL DEMANDED CERTIFICATE OF PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER, 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 (20) 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 attached to the notice of intent, is attached to the 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 Provider: Zurich Insurance Company, Attn: Records Custodian REILLY, JANICZEK & MCDEVITT, P.C. By: Le . Janiczek, Esquire Date: October 13, 2008 41 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LARRY M. KRICHMAR AND TINA L. KRICHMAR, h/w . PLAINTIFFS 08-3522 File No. VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER DEFENDANTS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Zuf * Insurance Company, 7045 College Blvd., Overland Park, KS 66211, Attn: Records Custodian (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: Any and all information with respect to any illness, medical history, consultations, prescriptions, andinr trPatments ' including but not limited to any and all records, notes, charges, x-rays, films, slides, reports, bills, billing statements, etc., on behalf of Barbara Edwards, DOB 08/11/1955, SS # 190-44-7075. Reilly Janiczek & McDevitt, P.C., The Widener Bldg.,1 S. Penn Sq., Ste. 410, Phila., PA 19107 at (Address) 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: NAe J. Janiczek, Esquire ADDS t s. Tenn bq., rnua., rA lyiu i TELEPHONE: () SUPREME COURT ID ATTORNEY FM33 V15) 972 520 Defendants, Charity E. LitchenbergeriE COURT: Andrew M. Litchenberger Prothonotary, Civil Division Date: 'Seal of the Court Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3522 CIVIT TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Zurich Insurance Company 7045 College Blvd. Overland Park, KS 66211 Attn: Records Custodian To: Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 Reilly, Janiczek & McDevitt on behalf of Defendants, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER, intends to serve a subpoena identical to the one that is attached to this notice. Please note that you have twenty (20) days from the date listed below within which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty (20) day notice period is waived or if no objection is made, then the subpoena may be served. REILLY, JANICZEK & McDEVITT, P.C. By._(L Lee J. iczek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M. Litchenberger Date: August 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W No.: 08-3522 VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER HIPAA COMPLIANT STATEMENT PURSUANT TO 45 CFR 164.512, "NOTICE" To: Zurich Insurance Company, 7045 College Blvd., Overland Park, KS 66211 Notice of the attached request for protected medical information was given to the Plaintiff's Attorney in the above-captioned case, who is authorized to accept all legal notices to the Plaintiff in this matter. See attached Notice of Intent to Serve Subpoena. The Notice of Intent to serve subpoena specifically references the protected health information sought, the time for objection has elapsed, and no objections were filed or the objections were waived. See attached Notice of Intent to Serve Subpoena. Thank you for your prompt attention to this matter. REILLY, JANICZEK & McDEVITT, P.C. By: Lee J. a iczek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M. Litchenberger Date: Aueust 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. No.: 08-3522 CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER REQUEST TO WAIVE 20 DAY NOTICE PERIOD PROVIDED IN RULES 4009.21 AND 4009.22 Custodians: Zurich Insurance Company 7045 College Blvd Overland Park, KS 66211 Attn: Records Custodian Counsel Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 I agree to waive 20 day notice period: Date: Signature REILLY, JANICZEK & MCDEVITT, P.C. BY: LEE J. JANICZEK, ESQUIRE IDENTIFICATION NO. 68433 WIDENER BUILDING, SUITE 410 ONE SOUTH PENN SQUARE PHILADELPHIA, PENNSYLVANIA 19107 (215) 972-5200 ATTORNEY FOR DEFENDANT, CHAIRTY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. KITCHENBERGER CUMBERLAND COUNTY NO. #08-3522 JURY TRIAL DEMANDED CERTIFICATE OF PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER, 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 (20) 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 attached to the notice of intent, is attached to the 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 Provider: Bureau of Workers' Compensation, Attn: Records Unit REILLY, JANICZEK & MCDEVITT, P.C. By: Lee J J iczek, Esquire Date: October 13, 2008 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LARRY M. KRICHMAR AND TINA L. KRICHMAR, h/w PLAINTIFFS 08-3522 File No. VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER DEFENDANTS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Btq&u of Workers' Compensation, 1171 South Cameron Street, Harrisburg, PA 17104- 2501 Attn: Records Unit (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: prescriptions, and/or treatments, including but not limited to any and all records, notes, charges, x-rays, films, slides, reports, bills, billing statements, etc.- on behalf of Barbara Edwards DOB 0811111955, S_R 9 190-44-7075. RefiITianic7ek & 1V cDev*ttl P C, The WodeSer Bldg.,1 S Penn Sq., Ste 410, Phi., PA 19107 (Address) 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: ADDRESS1. Janiczek, Eguire •, •> , T'ELWBONnn Sq-, Phila-. PA 19107 SUPREME COURT 0 ATTORNEY FOR: - 68433 BY THE COURT: Defendants, Charity E. Litchenberger & Andrew M. Litchenberger Prothonotary, Civil Division Date: 'Seal of the Court Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3522 CIVIT TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Bureau of Workers' Compensation 1171 South Cameron Street, Room 109 Harrisburg, PA 17104-2501 Attn: Records Unit To: Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 Reilly, Janiczek & McDevitt on behalf of Defendants, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER, intends to serve a subpoena identical to the one that is attached to this notice. Please note that you have twenty (20) days from the date listed below within which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty (20) day notice period is waived or if no objection is made, then the subpoena may be served. REILLY, JANICZEK & McDEVITT, P.C. By.- L? Lee J J iczek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M. Litchenberger Date: AuLrust 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W No.: 08-3522 VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER HIPAA COMPLIANT STATEMENT PURSUANT TO 45 CFR 164.512, "NOTICE" To: Bureau of Workers' Compensation, 1171 South Cameron Street, Room 109, Harrisburg, PA 17104-2501, Attn: Records Unit Notice of the attached request for protected medical information was given to the Plaintiff's Attorney in the above-captioned case, who is authorized to accept all legal notices to the Plaintiff in this matter. See attached Notice of Intent to Serve Subpoena. The Notice of Intent to serve subpoena specifically references the protected health information sought, the time for objection has elapsed, and no objections were filed or the objections were waived. See attached Notice of Intent to Serve Subpoena. Thank you for your prompt attention to this matter. REILLY, JANICZEK & McDEVITT, P.C. By: DO Lee J J niczek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M, Litchenberger Date: Aueust 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER No.: 08-3522 REQUEST TO WAIVE 20 DAY NOTICE PERIOD PROVIDED IN RULES 4009.21 AND 4009.22 Custodians: Bureau of Workers' Compensation 1171 South Cameron Street, Room 109 Harrisburg, PA 17104-2501 Attn: Records Unit Counsel Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 I agree to waive 20 day notice period: Signature Date: c? +v .? M w REILLY, JANICZEK & MCDEVITT, P.C. BY: LEE J. JANICZEK, ESQUIRE IDENTIFICATION NO. 68433 WIDENER BUILDING, SUITE 410 ONE SOUTH PENN SQUARE PHILADELPHIA, PENNSYLVANIA 19107 (215) 972-5200 LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. KITCHENBERGER ATTORNEY FOR DEFENDANT, CHAIRTY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER CUMBERLAND COUNTY NO. #08-3522 JURY TRIAL DEMANDED CERTIFICATE OF PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER, 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 (20) 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 attached to the notice of intent, is attached to the 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 Provider: Holy Spirit Hospital, Attn: Radiology Department REILLY, JANICZEK & McDEVITT, P.C. By: LC 1A11,0 L Janiczek, Esquire Date: October 13, 2008 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LARRY M. KRICHMAR AND TINA L. KRICHMAR, h/w PLAINTIFFS 08-3522 File No. VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER DEFENDANTS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 H(40pirit Hospital, 503 N. 21" Street, Camp Hill, PA 17011, Attn: Radiology Department (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all information with respect to any illness, medical history, consultations, prescriptions, and/or treatm _n c, including but not Ilmitad to an,) and all reCordc notes charges, x-rays, films Slides reports, bills, billing statements, etc., on behalf of Barbara Edwards, DOB 08/11/1955, SS # 190-44-7075. Reilly Janiczek & McDevitt, P.C., The Widener Bldg., 1 S. Penn Sq., Ste. 410, Phila., PA 19107 (Address) 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: NAN&e J. Janiczek, Esquire ADD4W WidPnP- 21d9 I Ste., 44(;-- 1 q., i a., PA 1 TELEPHONE: SUPREME COURT ID ATTORNEY 1433 Defendants, Charity E. LitchenbergerIE COURT: Andrew M. Litchenberger Date: 'Seal of the Court Prothonotary, Civil Division Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3522 CIVIT TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Holy Spirit Hospital 503 N 21St Street Camp Hill, PA 17011 Attn: Radiology Department To: Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 Reilly, Janiczek & McDevitt on behalf of Defendants, CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER., intends to serve a subpoena identical to the one that is attached to this notice. Please note that you have twenty (20) days from the date listed below within which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty (20) day notice period is waived or if no objection is made, then the subpoena maybe served. REILLY, JANICZEK & WDEVITT, P.C. By: / Lee J. A;; iczek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M. Litchenberger Date: August 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M. KRICHMAR AND TINA L. KRICHMAR, H/W No.: 08-3522 VS. CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER HIPAA COMPLIANT STATEMENT PURSUANT TO 45 CFR 164.512, °NOTICE" To: Holy Spirit Hospital, 503 N 21s' Street, Camp Hill, PA 17011, Attn: Radiology Department Notice of the attached request for protected medical information was given to the Plaintiff's Attorney in the above-captioned case, who is authorized to accept all legal notices to the Plaintiff in this matter. See attached Notice of Intent to Serve Subpoena. The Notice of Intent to serve subpoena specifically references the protected health information sought, the time for objection has elapsed, and no objections were filed or the objections were waived. See attached Notice of Intent to Serve Subpoena. Thank you for your prompt attention to this matter. REILLY, JANICZEK & McDEVITT, P.C. By: ` Lee J. an zek, Esquire Attorney for Defendant, Charity E. Litchenberger and Andrew M, Litchenberger Date: Aueust 21, 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LARRY M, KRICHMAR K=MM R, H/W AND TINA L. VS. No.: 08-3522 CHARITY E. LITCHENBERGER AND ANDREW M. LITCHENBERGER REQUEST TO WAIVE 20 DAY NOTICE PROVIDED IN RULE PERIOD S 4009.21 AND Custodians: Holy Spirit Hospital 503 N 21 st Street Camp Hill, PA 17011 Attn: Radiology Department Cow Herschel Lock, Esquire Attorney at Law 3107 N. Front Street Harrisburg, PA 17110 I agree to waive 20 day notice period: Date: Signature c r?. a? LARRY M. KRICHMAR and TINA L. KRICHMAR, husband and wife Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-03522 CHARITY E. LICHTENBERGER CIVIL ACTION - LAW and ANDREW M. LICHTENBERGER, Defendants PRAECIPE TO SATISFY TO THE PROTHONOTARY: Please mark the above captioned action as being "settled and discontinued". DATED: October 2009 HERSCHEL LOCK, ESQUIRE Attorney for Plaintiffs 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 Supreme Court No. 22691 R.El ! 1 2 90,9 G:, c 19 P 1 1 L: 02