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Home My WebLink About04-160517t'nnison ROBERT E. DENNION, JR, and MERRY E. DENNISON, Husband and Wife, 4235 Guinea Road Annandale, VA 22003 Plaintiffs VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PA CIVIL ACTION - LAW CHARLES A. CORKLE, JR., 671 Anderstown Road : No. CV - - 2004 lke0 ' Dover, PA 17315, Defendant : JURY TRIAL DEMANDED PRAECIPE FOR APPEARANCE AND ISSUANCE OF WRIT OF SUMMONS TO: The Prothonotary Please enter our appearance for the Plaintiff in the above action and issue a Writ of Summons against Charles A. Corkle, Jr., Defendant. CARPENTER & EDMUNDS y l2 o y BY J J Edmunds, Esquire 0) '?Zl o ey I.D.#69593 101 North Eleventh Street Sunbury, PA 17801 (570)286-7000 Attorney for Plaintiffs DeoVtisor, ROBERT E. DENNION, JR, and MERRY E. DENNISON, Husband and Wife, 4235 Guinea Road Annandale, VA 22003 Plaintiffs VS. CHARLES A. CORKLE, JR., 671 Anderstown Road Dover, PA 17315, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PA CIVIL ACTION - LAW No. CV - - 2004 JURY TRIAL DEMANDED WRIT OF SUMMONS TO: Charles A. Corkle, Jr., Defendant You are hereby notified that Robert E. Dennison, Jr. and Merry E. Dennison, husband and wife, have commenced an action against you on account of injuries they received in an automobile accident which occurred on April 20, 2002. , Prothonotary -1 BY:q?? t??1 DATED: /? 7C?? I i l V^ .i. a? r 4 ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife Plaintiff, vs CHARLES A. CORKLE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 04-1605 Civil Term JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Charles A. Corkle, Jr., with regard to the above-captioned matter. Date: S 7 LO7 Respectfully submitted, NEALON & GOVER:, P.C. By:'V1 ct- o Michael S. Ferguson I.D. #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this ;?O? day of May, 2004, I hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 -M'(C ' Michael S. Ferguson, Esquire ^--; ' ? ? J - - ? n _t :> '. .r ? rn ? r.? ? _; .? C'c? -.. , -c -, .- ?, :. :, ; ,; •'? .: _ cn =_ ?; ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs CHARLES A. CORKLE, JR., Defendant. No.: 04-1605 Civil Term .JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer ajudgment of non pros. Date: TO THE PLAINTIFF: Respectfully submitted, NEALON & GOVLR, P.C. By: Michael S. Ferguson, sgmre LD. #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 RULE A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DA"f ED: !C) Prothonotary 77 _r T SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-01605 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DENNISON ROBERT E JR ET AL VS CORKLE CHARLES A JR R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: CORKLE CHARLES A JR but was unable to locate Him deputized the sheriff of YORK in his bailiwick. He therefore serve the within WRIT OF SUMMONS County, Pennsylvania, to On June 16th , 2004 , this office was in receipt of the attached return from YORK Sheriff's Costs: So answers -' Docketing 18.00 Out of County 9.00 Surcharge 10.00 R! Thomas Feline Dep York County 27.50 Sheriff of Cumberland County .00 64.50 06/16/2004 CARPENTER & EDMUNDS Sworn and subscribed to before me this day of A. D. Prothonotary z ?- /i1) -I COUNTY OF YORK OFFICE OF THE SHERIFF S(17)771 RIC CALL 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LNE 1 THRU 12 DO NOT DETACH ANY COPES 1. PLAINTIFFISI Robert E. Dennison Jr et al 3. DEFENDANTISI Charles A. Corkle Jr. 2. COURT NUMBER 2004-1605 Civil 4. TYPE OF WRIT OR COMPLAINT Writ of Summons SERE ¦ 5. NAME OF INDIVIDUAL, COMPANY. CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD `¦j¦\ Charles A. Corkle Jr. 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO.. CITY, BORO. TwP.. STATE AND ZIP CODE) AT 671 Andersontown Road Dover, PA 17315 7. INDICATE SERVICE: U PERSONAL U PERSON IN CHARGE NDEPUTIZE U CE T. IL U 1ST CLASS MAIL U POSTED U OTHER NOW April 16 20 04 I, SHERIFF OCOUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute thi ake return t ccording to law. This deputization being made at the request and risk of the plaintiff. d ; SHERIFF OF COUNTY 6. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WALL ASSIST IN EXPEDITING SERVICE Cumberland Out of County - AnvAw p.. Pr?r. PD BY CUMRRRLAND CTY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for arty loss. destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY I ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED JEFFREY P. EDMUNDS, ESQ 101 NORTH ELEVENTH ST. SUNBURY PA 17801 570-286-7000 04-15-2004 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW. (This. area must be completed a notes is to be mailed). CUMBERLAND COUNTY SHERIFF'S DEPT. ACE 8 I'+ 11th THS M, 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date or complaint as Indicted above. RONDA M. AHRENS / RAT 104-19-2004 I 05-15-2004. 16. HOW SERVED: PERSONAL I)d RESIDENCE( ) POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O 1 hereby certify and a NOT OUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 1 D L OF INDIV S VED I LIST A( RESS HERE IF OT ISHOWN ABOVE (Relationship to Dote ant) 19. D/a//n o Service 20. ?TTiiimmmee of S.ennce - ` 1? 6 r`-eS Q {-K vl r . 'Milos/P", Dal (Time Milesl Int. 27. A le h Mi L Data Time Miles Int. I Date Time 1 Miles Int. I Date 1 Tens Miles Int. I Data Tirr i I 1 22. REMARKS: ITY j 6r7-01 Costs 23. $ Adv 755.. 001s 24 Service Costa 25. NIF ?26. Mileage 27. Postage 26. Sub TO 129. Pound 1 30 Notary 37. SurMg. P 7 501 J q T Due Refund 1401 34. Foreign County Costs 135. Advance Coats 136. Service Costs 137. Notary Cert. 38. MseagHPoslagrlNot(yjyt Found 139. Total Costs 140. Costs Due or Refund 41. AFFIRMED and wbscribed to before me this 1 SO ANSWERS H. Sp. Sheaf 45 . DAME 12. sayd .200443. Dep. Sheriff Y A PROT ' un RY 46, Signature of 47. DT NOTARIAL SEAL CounlLSheriff /?' -JaSgd.SHAFFER;NOtary Public WILLy H M. (LOS" //L y/p,??? x-1-04 City al York, Yo?FAkC C ?/ >' mmi". Expir,(3s Ap? 49. Spnature of Foregn 49. DATE kF ? County Sheriff 50. 1 NOIALEDGE RECEIPT OF THE SHERIFF' ETU N SIGNATURE 151. DATE RECEIVED OF UTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office ROBERT E. DENNISON, JR, and : IN THE COURT OF COMMON PLEAS OF MERRY E. DENNISON, Husband and Wife, Plaintiffs vs. CHARLES A. CORKLE, JR., Defendant CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW No. 04-1605 Civil Term : JURY TRIAL DEMANDED NOTICE 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 upon you, 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 a judgment may be entered against you by the Court without further notice to you 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 YOU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 - 9108 ROBERT E. DENNISON, JR, and : IN THE COURT OF COMMON PLEAS OF MERRY E. DENNISON, : CUMBERLAND COUNTY, PA Husband and Wife, Plaintiffs : CIVIL ACTION - LAIN VS. No. 04-1605 Civil Terna CHARLES A. CORKLE, JR., Defendant : JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff, Robert E. Dennison, Jr., is an adult individual residing at 4235 Guinea Road, Annandale, Virginia 2203. 2. Plaintiff, Merry E. Dennison, is an adult individual residing at 4235 Guinea Road, Annandale, Virginia 2203. 3. Defendant, Charles A. Corkle, Jr., is an adult individual with a last known principal residence address of 671 Anderstown Road, Dover, Pennsylvania 17315. 4. At all times relevant hereto, the Defendant was the owner and operator of a 1994 GMC Jimmy, with a Vehicle Identification Number of 1GKDT13W6R0509154, and a Pennsylvania license plate number of EHK3909. 5. At all times relevant hereto, the Plaintiffs were the owners of a 1992 Ford E- 150 Econoline Conversion Van, with a Vehicle Identification Number of 1FDEE14N3NHB54404, and a Pennsylvania license plate nurnber of 523612M. 6. On April 20, 2002, Plaintiff, Robert E. Dennison, Jr., was operating his vehicle on State Route 83, travelling in a northerly direction, at or near milepost 40.8, in Cumberland County, Pennsylvania. Plaintiff, Merry E. Dennion, was a passenger in the Plaintiffs' vehicle. 7. At the afore-mentioned time and location, the roadway is a divided highway, with two lanes travelling in the northerly direction, where the posted speed limit is generally 55 miles per hour. 8. At the aforesaid location the Defendant was operating his vehicle in a northerly direction on State Route 83, immediately behind the Plaintiffs' vehicle. 9. At the aforesaid location, traffic, including Plaintiffs' vehicle was stopped due to congestion. 10. At the aforesaid time and location, Defendant failed to stop his vehicle, and the Defendant's vehicle collided with Plaintiffs' vehicle from the rear. 11. The collision referenced above was caused solely by the negligence of the Defendant, said negligence consisting of. (a) Failing to operate his vehicle in a safe manner; (b) Failing to operate his vehicle in accordance with Motor Vehicle Code laws and regulations; (e) Failing to have his vehicle under control; (d) Failing to keep a proper lookout; (e) Failing to take evasive action; (f) Failing to properly adhere to traffic control markings; and (g) Causing his vehicle to collide with the Plaintiffs vehicle. COUNTI ROBERT E. DENNISON, JR. v. CHARLES A. CORKLE, JR. 12. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference as if set forth at length. 13. Solely due to the Defendant's negligence and the above-mentioned collision, the Plaintiff, Robert E. Dennison, Jr., has suffered serious, painful and permanent personal injuries including but not limited to: A) traumatic strain/sprain to cervicothoracic areas; B) traumatic strain/sprain to lumbosacral areas; C) Recurrent severe aches and pains; 14. Solely as a result of the aforesaid negligence of the Defendant, the Plaintiff, Robert E. Dennison, Jr., has undergone great physical pain and mental anguish, and he will continue to endure the same for an indefinite time in the future to his great detriment and loss. 15. The above mentioned injuries received by the Plaintiff, Robert E. Dennison, Jr., have decreased his ability to enjoy life and life's pleasures. 16. Solely as a result of the aforesaid negligence of the Defendants, the Plaintiff, Robert E. Dennison, Jr., has undergone great physical pain and mental anguish, and he will continue to endure the same for an indefinite time in the future to his great detriment and loss. WHEREFORE, Plaintiff, Robert E. Dennison, Jr., demands judgment against the Defendants jointly and severally in an appropriate amount to compensate him for the injuries he sustained. COUNT II MERRY E. DENNISON v. CHARLES A. CORKLE, JR. 17. Paragraphs I through 16 of this Complaint are incorporated herein by reference as if set forth at length. 18. Solely due to the Defendant's negligence and the above-mentioned collision, the Plaintiff, Merry E. Dennison, has suffered serious, painful and permanent personal injuries including but not limited to: A) traumatic hyperextension/hyperflexion strain/sprain to her cervicothoracic area; B) ) traumatic hyperextension/hyperflexion strain/sprain to her lumbosacral area; Q Recurrent severe aches and pains; D) Difficulty in sleeping due to pain; E) Headaches. 19. Solely as a result of the aforesaid negligence of the Defendants, the Plaintiff, Merry E. Dennison, has undergone great physical pain and mental anguish, and she will continue to endure the same for an indefinite time in the future to her great detriment and loss. 20. The above mentioned injuries received by the Plaintiff, Merry E. Dennison, have decreased her ability to enjoy life and life's pleasures. 21. Solely as a result of the aforesaid negligence of the Defendants, the Plaintiff, Merry E. Dennison, has undergone great physical pain and mental anguish, and she will continue to endure the same for an indefinite time in the future to her great detriment and loss. WHEREFORE, Plaintiff, Merry E. Dennison, demands judgment against the Defendants jointly and severally in an appropriate amount to compensate her for the injuries she sustained. Edmunds, Esquire 1LD.#69593 Sunbury, PA 17801 (570)286-7000 Attorney for Plaintiffs 101 North Eleventh Street VERIFICATION - SWORN Jeffrey P. Edmunds, Esquire, being duly sworn according to law deposes and says that he is authorized on behalf of the Plaintiff to verify the facts of the attached Complaint, that the client is not available to execute this verification within the time allotted for filing this Complaint, and that the facts set forth in the foregoing are true and correct to the best of his knowledge and belief. ROBERT E. DENNISON, JR, and : IN THE COURT OF COMMON PLEAS OF MERRY E. DENNISON, : CUMBERLAND COUNTY, PA Husband and Wife, Plaintiffs : CIVIL ACTION - LAW VS. No. 04-1605 Civil Terin CHARLES A. CORKLE, .JR., Defendant : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Jeffrey P. Edmunds, Esquire, hereby certifies that on the / 9 day o die 2004, he served a copy of the foregoing Complaint upon the Defendant by mailing the same by regular first-class mail, postage pre-paid to the following: Michael S. Ferguson, Esquire 2411 North Front Street Harrisburg, PA 17110 CARPENTER & EDMUNDS Esquire ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife Plaintiff, vs CHARLES A. CORKLE, JR., Defendant. No.: 04-1605 Civil Term JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Robert Dennison and Merry E. Dennison C/o Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein contains averments against you to which you are required' to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, Date: 1 ( k IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NEALON & GOVER, P.C. By: Michael S. Fergus n, Esquire I.D. #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 ROBERT DENNISON, and IN THE COURT OF COMMON PLEAS MERRY E. DENNISON, Husband CUMBERLAND COUNTY, PENNSYLVANIA And Wife Plaintiff, vs No.: 04-1605 Civil Term CHARLES A. CORKLE, JR., Defendant. JURY TRIAL DEMANDED ANSWER WITH NEW MATTER 1. Admitted based on information and belief. 2. Admitted based on information and belief. 3. Denied. The Defendant's current address is 697 E. Butter Rd., York, PA 17401. 4. Admitted. 5. Admitted in part, denied in part. It is admitted that the vehicle involved and the identification number of the vehicle are stated correctly in the Complaint. It is denied that the vehicle is licensed in Pennsylvania. In fact, the vehicle is licensed in the State of Maryland with the same license plate number. 6. Amitted. 7. Admitted. 8. Admitted. 9 - 11. Denied pursuant to Pa. R.C.P. 1029(e). COUNTI thereto. 12. Paragraphs 1 through 11 of this Answer are incorporated herein by reference 13 - 16. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant Charles Corkle, Jr. demands judgment be entered in his favor and against the Plaintiffs with costs to be placed upon the Plaintiffs. COUNT If MERRY E. DENNISON V. CHARLES A. CORKLE. JR 17. Paragraphs 1 through 16 of this Answer are incorporated herein by reference thereto. 18 - 21. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant Charles Corkle, Jr. demands judgment be entered in his favor and against the Plaintiffs with costs to be placed upon the Plaintiffs. NLW MATTER 22 thereto. 23. Pennsylvania Motor Vehicle Financial Responsibility Act. Paragraphs 1 through 22 of this Answer are incorporated herein by reference The Plaintiffs' claims may be barred in whole or in part by application of the WHEREFORE, Defendant Charles A. Corkle, Jr. demands judgment be entered in his favor and against the Plaintiffs with costs to be placed upon the Plaintiffs. Respectfully submitted, Date: Lo? NEALON & GOVER, P.C. By: Michael erguson I.D. #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 VERIFICATION I, CHARLES A. CORKLE, JR., verify that the statements made in the foregoing ANSWER WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 1a Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: /2 O CERTIFICATE OF SERVICE AND NOW, this 101 day of August, 2004, 1 hereby certify that I have served the foregoing ANSWER WITH NEW MATTER on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 -pW Michael S. Ferguson, Esquire '„ ( ?:' ; O i ? (17 `:,' ? -. ?;? :.:f f ? ?'ry T I ?, - .. ROBERT DENNISON, and MERRY E. DENNISON, husband And Wife Plaintiffs VS. CHARLES A. CORKLE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No.: 04-1605 Civil Term CIVIL ACTION - LAW PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER AND NOW, comes the Plaintiffs, by and through counsel, CARPENTER & EDMUNDS, to respond to the Defendant's New Matter as follows: Paragraph 22 - No responsive pleading required Paragraph 23 - The allegations contained in Paragraph 23 of Defendant New Matter are conclusions of law which no further response is required. WHEREFORE, the Plaintiffs hereby requests relief has set forth in their Complaint. Respectfully submitted, Jef 1ds, Esquire ByMheveenth _ 10Street Sunbury, PA 17801 (570) 286 -7000 Counsel for Plaintiff VERIFICATION - SWORN sworn according to law deposes and says Jeffrey P. Edmunds, Esquire, being duly the facts of the attached Reply to that he is authorized on behalf of the Plaintiff to verify oin are true and correct to Defendants New Matter, and that the facts set forth in the foreg g the best of his knowledge and belief. f? 114 L( F EDMUNDS, ESQUIRE ROBERT DENNISON, and MERRY E. DENNISON, husband And Wife Plaintiffs VS. CHARLES A. CORK Defendant IN THE COURT OF COMMON PLEAS OF CUMBEKL.AND COUNTY No.: 04-1605 Civil Term CIVIL ACTION - LAW CERTIFICATE OF SERVICE Jeffrey P. Edmunds, Esquire, hereby certifies that on the 9th day of September, 2004, he served the foregoing document upon the Defendant by sending the same, by first class mail, postage prepaid, to her counsel as follows: Michael S. Ferguson, Esquire NEALON & GOVER, P 2411 North Front Street Harrisburg, Pa 17110 Respectfully submitted, Sunbury, PA 17801 (570) 286 - 7000 Counsel for Plaintiff CARPENTER & EDINDS 0 /I By. Esquire Jeff P geenth s, 101 ort Street {? f1l =? ?-? C__n it !"ii 1 fir; _ - . _L r ? ,` ? rr: ?: . "' ?_ jl? r ,(? ? ? ? ,?(?7 -? G] CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -vs- CHARLES CORKLE, JR. COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MCS on behalf o MI IAE PER,USON!kE ? , Attorney for DEFENDANT DE11-544117 7 8 9 0 1- 1, 0 1 C O M M O N W E AL T H OP PE NN S Y LVAN T A COUNT Y OP CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. NOTICE SERVE A HARRISBURG HOSPITAL HARRISBURG HOSPITAL JACKSONVILLE CHIROPRACTIC CTR FAMILY CHIROPRACTIC CENTER FAIRVIEW TOWNSHIP EMS DR_ NANCY HAFNER ERIE INSURANCE GROUP MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE TERM, CASE NO: 04-1605 1 TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290629 7 8 9 0 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON VS. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at 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: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N FRONT ST HARRISBURG. PA 17110 TELEPHONE: (215).246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY T E COURT: Prothonotary/Clerk, Civ Did t /o_Lt? 02 1 ann Deputy - Dale: Seal of the Court 78901-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 78901 MERRY DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary 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 : MERRY DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security #: 405-88-0397 Date of Birth: 11-22-1964 SU10-545116 7 8 9 0 1- 1, 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON TERM, -VS- CASE NO: 04-1605 CHARLES CORKLE, JR. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-544118 78901--L,02 C O M M O N W E A L T H OF, P E NN S Y L VANS A COUNTY OP C UM B E R L -AND IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. TERM, CASE NO: 04-1605 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUKENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HARRISBURG HOSPITAL HARRISBURG HOSPITAL JACKSONVILLE CHIROPRACTIC CTR FAMILY CHIROPRACTIC CENTER FAIRVIEW TOWNSHIP EMS DR. NANCY HAFNER ERIE INSURANCE GROUP MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 MCS on behalf of CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - Any questions regarding this matter, contact MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290629 7 8 9 0 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON VS. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800, Philadelpbia 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: MICHAEL FERGUSON, ESO. ADDRESS: 7411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ?, /? t-- 1 _ 21 ?z0 Seal of the Court BY T E COURT.- Prothonotary/Clerk, Civil id Deputy 78901-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 78901 MERRY DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. ALL DIAGNOSTIC FILMS. Subject : MERRY DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security #: 405-88-0397 Date of Birth: 11-22-1964 SU10-545118 7 8 9 0 1- L 02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 CHARLES CORRLE, JR. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-544119 78901-1,03 C O M M ON W E AL T H COUNTY IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. INTENT TO HARRISBURG HOSPITAL HARRISBURG HOSPITAL JACKSONVILLE CHIROPRACTIC CTR FAMILY CHIROPRACTIC CENTER FAIRVIEW TOWNSHIP EMS DR. NANCY HAFNER ERIE INSURANCE GROUP TO MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - Any questions regarding this matter, contact OF P E N N S Y L VAN I A O F C U M B E R L AN D THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290629 78903--C!02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON vs. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JACKSONVILLE CHIROPRACTIC TR (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 Group In 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: MICHAEL FERGUSON. ESO ADDRESS: 2411 N. FRONT ST. HARRISBURG-PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant rn Date: ?/_ octJ? o?s Seal of the Court BY THE COURT: Prothoonnotary/Cllerrk,, Civil ivi C y//Qz, o riJ? r Deputy 78901-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JACKSONVILLE CHIROPRACTIC CTR 14307 JARRETTSVILLE PIKE P.O. BOX 38 PHOENIX, MD 21131 RE: 78901 MERRY DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE DIAGNOSTIC FILMS 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 : MERRY DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security k: 405-88-0397 Date of Birth: 11-22-1964 SU10-545120 7 8 9 0 1- L 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 CHARLES CORKLE, JR. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-544120 7 8 9 0 1- 1, 0 4 C O M M O N W E A L T H OF' P E NN S Y L VAN-TA COUNTY OP C U M S E R L AI STD IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 CHARLES CORKLE, JR. INTENT TO THINGS FOR DI HARRISBURG HOSPITAL HARRISBURG HOSPITAL JACKSONVILLE CHIROPRACTIC CTR FAMILY CHIROPRACTIC CENTER FAIRVIEW TOWNSHIP EMS DR. NANCY HAFNER ERIE INSURANCE GROUP TO PRODUCE RULE MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290629 7 8 9 0 3-- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON vs. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for FAMILY CHIROPRACTIC CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** 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: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: .J?Z' oZ / ?') 6?6r Seal of the Court BY THE COURT: LProthonotary/Clerk, Civil Divisi n Deputy 78901-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FAMILY CHIROPRACTIC CENTER 10831 MAIN STREET FAIRFAX, VA 22030 RE: 78901 MERRY DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE DIAGNOSTIC FILMS. 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 : MERRY DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security 11: 405-88-0397 Date of Birth: 11-22-1964 SU10-545122 78901--L,04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON TERM, -vs- CASE NO: 04-1605 CHARLES CORKLE, JR. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-544121 7 8 9 0 1- L 0 5 C O M M O N W E A L T H OP P E N N S Y L VANS-A, COUNTY OF' C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. TERM, CASE NO: 04-1605 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUKKNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HARRISBURG HOSPITAL HARRISBURG HOSPITAL JACKSONVILLE CHIROPRACTIC CTR FAMILY CHIROPRACTIC CENTER FAIRVIEW TOWNSHIP EMS DR. NANCY HAFNER ERIE INSURANCE GROUP MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 MCS on behalf of CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - Any questions regarding this matter, contact MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290629 7 8 9 0 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON VS. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for FAIRVIEW TOWNSHIP EMC (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 Crm}p In 1601 Market Street Suite 800 Philadelp 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: MICHAEL FERGUSON. ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215)246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: -de4?? 21 '.. kl? ze? Prothonotary/Clerk, Civil DDivis Deputy Date: \ [ r oZLXJ.C- _ Seal of the Court 78901-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FAIRVIEW TOWNSHIP EMS 513 FISHING CREEK RD LEWISBERRY, PA 17339 RE: 78901 MERRY DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 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 : MERRY DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security tf: 405-88-0397 Date of Birth: 11-22-1964 SU10-545124 7 8 9 0 1- 1, 0 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 CHARLES CORKLE, 3R. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ, Attorney for DEFENDANT DE11-544122 78903--T,06 C O M M O N W E A L T H OP P E NN S Y L VAN T A COUNT Y OP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. TERM, CASE NO: 04-1605 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUNffigTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HARRISBURG HOSPITAL HARRISBURG HOSPITAL JACKSONVILLE CHIROPRACTIC CTR FAMILY CHIROPRACTIC CENTER FAIRVIEW TOWNSHIP EMS DR. NANCY HAFNER ERIE INSURANCE GROUP MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 MCS on behalf of CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290629 7 8 9 0 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON vs. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. NANCY HAFNER (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 Groun_ 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: MICHAEL FERGUSON. ESO ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant I' - -: _5 BY TliE COURT: Date: Deputy ?SSeal of the Court 78901-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR DR. NANCY HAFNER 855 D. ARLINGTON BLVD. STE 201 FAIRFAX, VA 22031 RE: 78901 MERRY DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE DIAGNOSTIC FILMS. 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 : MERRY DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security k: 405-88-0397 Date of Birth: 11-22-1964 SU10-545126 7 8 9 0 1- L 0 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -VS - COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 CHARLES CORKLE, JR. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-544123 7 8 9 0 1- L 07 C O M M O N W E A L T H OF P E N N S Y L VAN 2 A COUNTY OF, CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. HARRISBURG HOSPITAL HARRISBURG HOSPITAL JACKSONVILLE CHIROPRACTIC CTR FAMILY CHIROPRACTIC CENTER FAIRVIEW TOWNSHIP EMS DR. NANCY HAFNER ERIE INSURANCE GROUP A SUBPOENA MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE TERM, CASE NO: 04-1605 AND TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 MCS on behalf of CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - Any questions regarding this matter, contact MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290629 7 8 9 0 1- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON vs. CHARLES CORKLE, JR. File No. 04-1605 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 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: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST HARRISBURG. PA 17110 TELEPHONE: (2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Deputy Date: ) C2 .1 L61!? Seal of the Court 78901-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ERIE INSURANCE GROUP 12121 TECH ROAD SILVER SPRING, MD 20904 RE: 78901 MERRY DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. CLAIM #010210398872 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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 plaintiff's 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 : MERRY DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security #: 405-88-0397 Date of Birth: 11-22-1964 Date of Loss: 04/20/2002 SU10-545128 7 8 9 0 1- L 0 7 ?? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -vs- CHARLES CORKLE, JR. COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 ',MCS on behalf of. MICR EL FE?RGUSOjNN,, Es o. Attorney for DEFENDANT DE11-544125 78927-1,01 C O M M O N W E A L T H OP P E NN S Y L VAN T A COUNTY OF' C U M B E R L .AND IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. TERM, CASE NO: 04-1605 JCB DOCUMENTS AND 4009.21 JACKSONVILLE CHIROPRACTIC CTR MEDICAL RECORDS HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL OTHER TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290574 '78 92 7-CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON VS. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JACKSONVILLE CHIROPRACTIC CTR (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 GrojW. 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: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 171 10 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Civil FEB 1 6 2005 Date: Deputy Seal of the Court 78927-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JACKSONVILLE CHIROPRACTIC CTR 14307 JARRETTSVILLE PIKE P.O. BOX 38 PHOENIX, MD 21131 RE: 78927 ROBERT DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDE DIAGNOSTIC FILMS. 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 : ROBERT DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security #: 415-17-0333 Date of Birth: 01-22-1962 SU10-545132 7 8 9 2 7- L 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 CHARLES CORKLE, JR. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-544126 78927-L 02 C O M M O N W E A L T H OF PEN N S Y L VAN I A COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON -vs- CHARLES CORKLE, JR. INTENT TO SERVE A JACKSONVILLE CHIROPRACTIC CTR MEDICAL RECORDS HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL OTHER TERM, CASE NO: 04-1605 E DOCUMENTS AND TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUR - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290574 7 8 9 2 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON VS. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for H RRI B TR 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: **** 4 ATTACHED RIDER **** at The MCS Croun 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: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: 151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant FE9 6 2005 Date: ? z -_ 02 ;_ Seal of the Court BY T E COURT: Prothon4otary/Clerk, Civil Diivvis' Deputy 78927-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 78927 ROBERT DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary 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 : ROBERT DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security t!: 415-17-0333 Date of Birth: 01-22-1962 SU10-545134 78 92 7- L O 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. TERM, CASE NO: 04-1605 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, 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: 02/16/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT COURT OF COMMON PLEAS DE11-544127 7 8 9 2 7- 1, 0 3 C O M M O N W E A L 7H OF P E N N S Y L VAN Z A COUNTY OF, C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON _VS_ CHARLES CORKLE, JR. W INTENT TO SERVE A TERM, CASE NO: 04-1605 AND JACKSONVILLE CHIROPRACTIC CTR MEDICAL RECORDS HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL OTHER TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, 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: 01/27/2005 CC: MICHAEL FERGUSON, ESQ. - 04-313 MICHAEL SMOLUK - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-290574 7 8 9 2 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON VS. CHARLES CORKLE, JR. File No. 04-1605 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Crotty Inc 1601 Market Street Suite 800 Philadelph4a 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: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG- PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant FE3 r 4505 Date: J? l1 0[ 241 ? Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil ivisi ti Deputy 78927-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 SOUTH FRONT STREET HARRISBURG, PA 17101 RE: 78927 ROBERT DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. ALL DIAGNOSTIC FILMS. Subject : ROBERT DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security #: 415-17-0333 Date of Birth: 01-22-1962 SU10-545136 78927-L 03 ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife Plaintiff, vs CHARLES A. CORKLE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 04-1605 Civil Term JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Charles A. Corkle, Jr., with regard to the above-captioned matter. Respectfully submitted, NEALON, GOVER & PERRY By: IdAl? Oasey G. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: 131117 16 CERTIFICATE OF SERVICE AND NOW, this 17T' day of March, 2005, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 Ca . Shore, Esquire ??, ?: C" ? ? f r ?? l 1\ i T?fr ? N `,>?r . -' ?_-? ,?; = " r: 4 5' N 2 ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife Plaintiff, vs CHARLES A. CORKLE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 04-1605 Civil Term JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, Charles A. Corkle, Jr., with regard to the above-captioned matter. Respectfully submitted, Date: o5 NEALON, GOVER & PERRY By: ktLj" /L 1-146? Michael S. Fer son, Esq ' e I.D. #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this i7-0? day of March, 2005, 1 hereby certify that I have served the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 ke? L4I? &4 6/ ) Michael S. F rguson, Esquire f`? /y c? c- 3° i? fit ,?C?" 1?° i C'" : ,':?? .- ?l ?. i , .,? :.?. Robert Dennison, and Merry E. Dennison, husband and wife Plaintiff VS. Charles A. Corkle, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1605 20 PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Jeffrey P. Edmunds, Esquire , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: I . The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ an amount subject to compulsory arbitration The counterclaim of the defendant in the action is NSA The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Michael S. Ferguson, Esquire 2411 North Fourth Street Harrisbure. PA 17110 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully subs 'ted, - - -------------- 4Jef y P.Edmunds, Esquire ORDER OF COURT AND NOW, petition, Esq., and 200 , in consideration of the foregoing Esq., and Esq.. are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, ('1 ORN 1 1101 It R. P.I cz, N T 1 V ? q ? y y Robert Dennison, and Merry E. Dennison, husband and wife Plaintiff Va. Charles A. Corkle, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-1605 20 PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Jeffrey P. Edmunds, Esquire , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ an amount subject to compulsory arbitration The counterclaim of the defendant in the action is N/A The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Michael S. Ferguson, Esquire 2411 North Fourth Street Harrisburg, PA 17110 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall he submitted. Respectfully subs ed, ------ - - - ------------ Je ey P. Edmunds, Esquire ORDER OF COURT AND OW, y , 200 (o, in consideration of to for oing petition, dQVJ A 12 /7 Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. M E COPY FROtA? and the 1Q whereat u"" nt0 ? ?b?awd Court at tarlisie, Pa. .? ,?.y By the Court, __A I r.. cJlifiMYYe.G`iY, Ri PA ti, 4Z. J )r' M1? v 1 PREREQUISITE TO SERVICE OF A SUBPOENA xJ?a PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ROBERT & MERRY DENNISON TERM, CUMBERLAND -VS- CASE NO: 04-1605 CHARLES CORKLE, JR. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, 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: 07/10/2006 A02Vbehalf ASEY ORE, ESQ. Att ey for DEFEN T R1.12 133-H DE11-0635365 78927-LO4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ROBERT & MERRY DENNISON -VS- CHARLES CORKLE, JR. COURT OF COMMON PLEAS TERM, CASE NO: 04-1605 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 STATE AUTO INSURANCE INSURANCE TO: JEFFREY P. EDMUNDS, ESQ., PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, 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: 06/20/2006 CC: CASEY SHORE, ESQ. - 04-313 MICHAEL SMOLUK - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.10S 133-H DE02-0335222 78927-CO2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT & MERRY DENNISON vs. File No. 04-1605 CHARLES CORKLE, JR. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for STATE AUTO INSURANCE (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 MCC Groan. Inc 1601 Mark t Street. Suite 800 Philadelphia PA 19104 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: CASEY SHORE ESO ADDRESS: 2411 N. FRONT CT HARRI B TR PA 17110 TELEPHONE: _(215) 246-0900 SUPREME COURT iD #: ATTORNEY FOR: Defendant II JUL 10 2006 Date: ?ILLt, S ,? C?UIo Seal of the Court 78927-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR STATE AUTO INSURANCE 4900 RITTER ROAD P. 0. BOX 2006 MECHANICSBURG, PA 17005 RE: 78927 ROBERT DENNISON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. CLAIM #MAEX268501611140, DOL: 11/14/01, POLICY #AMD2685016 ADJUSTER: RICHARD CHASE 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 plaintiff's 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 : ROBERT DENNISON 4235 GUINEA ROAD, ANNANDALE, VA 22003 Social Security #: XXX-XX-3333 Date of Birth: 01-22-1962 Date of Loss: 04/20/2002 R1.10S 133-H SU10-0628228 78927-L04 01% Derr g, i?-e.+t,?? is ?Vs 64,. 44 In The Court of Common Pleas of Cumberland 221 laintiff 'A+ County, Pennsylvania No.CS ? -?0 les 4. CPA le .k De endant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. *Sture"!& OIJ?M ?.S ? ? f'I.G w?f` V r^ Name (Chairman) 17 Law Firm a.` w . 4-iaLS? I Address ' J &r??se. City, zip # IMA 4 17? i e Name Law Firm z / oo n -Ikt 1. Address e'4'WP 7011 City, zip IP 18959 Award Signature Name Law Firm Address city, zip We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) i n. n e n ., it 1, ,. n n " -PA do r?6r( -i Y if 4 . T 3 1, Z^6 ). -.c 42 4o r s-: vi L, Oa- f 41 * . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: 0 -0,6 1-4 L4"1AAAL r ) Date of Award: - 0 - a u?nan Notice of Entry of Award Now, the A I day of , 20_a_, at 0: .6 , A M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 0190.00 By: ??.Pro onotary Deputy r C= ow I 4 V11- ploy i ?d fry Ov (ok COOP y? k i ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife Plaintiff, vs CHARLES A. CORKLE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 04-1605 Civil Term JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, Charles A. Corkle, Jr., with regard to the above-captioned matter. Respectfully submitted, Date: ad ??o NEALON, GOVER & PERRY By: ZA? se hore, Esquire 1. D. 5321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, thisday of September, 2006, 1 hereby certify that I have served the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 hore, Esquire -? i-_ _:? _? ? ;; ; ? , , , `,j , ?- ?_ .. _ , ;.;- ' ?,_ , _. , . ; ?r ' ;?? ?. , ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, vs No.: 04-1605 Civil Term CHARLES A. CORKLE, JR., Defendant. JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Charles A. Corkle, Jr., with regard to the above-captioned matter. Respectfully submitted, NEALON, GOVER & PERRY By: Date: a? Co Jenni lby Allen, Esquire I.D. it' 4 11 2411 rth ront Street Harrisbu , A 17110 717/232-9900 CERTIFICATE OF SERVICE n? AND NOW, this ? day of September, 2006, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 Jenni h'eWy Allen, Esquire ('?? '? } r ? ? `f 1 ?-... _ S _ ? , +7 r: G M1 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife Plaintiff, ; vs CHARLES A. CORKLE, JR., Defendant. File No.: 04-1605 Civil Term NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is given that Defendant appeals from the award of the board of arbitrators in this case on September 20, 2006. A jury trial is demanded (Check line if a jury trial is demanded. Otherwise jury trial is waived. I hereby certify that (1) the compensation of the arbitrators has paid. lant Note: The demand for jury trial on appeal froni.? Rule 1007.1(b). (b) No affidavit or verification is required. Adopted March 16, 1981, effective May 15, 1981. Kor Appellant arbitration is governed by CERTIFICATE OF SERVICE AND NOW, this?tl-? day of October, 2006, 1 hereby certify that I have served the foregoing NOTICE OF APPEAL FROM AWARD OF ARBITRATORS on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire 101 North Eleventh Street Sunbury, PA 17801 nni Henley Allen, Esquire C-) rv M=l 3c c wp r % PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( ) for JURY trial at the next term of civil court. ( % ) for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) Robert Dennison, and Merry E. Dennison, husband and wife ( ) Civil Action - Law ( g) Appeal from Arbitration (other) VS. (Plaintiff) Charles A. Corkle, Jr. The trial list will be called on and Trials commence on vs. (Defendant) Pretrials will be held on (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 04 Civil 1605 2007 Indicate the attorney who will try case for the party who files this praecipe: Plaintiff - Jeffrey P. Edmunds, Esquire Indicate trial counsel for other parties if known: Defendant - Michael S. Ferguson, Esquire Date: This case is ready for trial. Signed: ' Print effrey P. Edmunds, Esquire Attorney for: Plaintiff ROBERT DENNISON, and MERRY E. DENNISON, husband And Wife Plaintiffs vs. CHARLES A. CORKLE, JR., Defendant IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY No.: 04-1605 Civil Term CIVIL ACTION -LAW CERTIFICATE OF SERVICE Jeffrey P. Edmunds, Esquire, hereby certifies that on the 91h day of March, 2007, he served the foregoing Praecipe for Trial upon the Defendant's counsel by sending the same, by first class mail, postage prepaid, to as follows: Michael S. Ferguson, Esquire 2411 North Front Street Harrisburg, PA 17110 Respectfully submitted, CARPENTER & EDMUNDS By: (hj?El - Ce? I- Jeffr y . munds, Esquire 101 North Eleventh Street Sunbury, PA 17801 (570) 286 - 7000 t?;l N C? ?"? "r2 ,..., .;, ri ?? - ,a "' e _ ?., ?`-?. -?; ?rra? -` = °?. w „_ ?-? a ROBERT DENNISON AND, IN THE COURT OF COMMON PLEAS MERRY E. DENNISON, CUMBERLAND COUNTY, PENNSYLVANIA HUSBAND AND WIFE, PLAINTIFFS V. CHARLES A. CORKLE, JR., DEFENDANT 04-1605 CIVIL ORDER OF COURT AND NOW, this 27`' day of March, 2007, the non-jury trial in the above referenced case has been assigned to this Court. Prior to setting an actual trial date, IT IS HEREBY ORDERED AND DIRECTED that the parties in this case file a pre-trial memorandum with the Court on or before April 20, 2007 in the following format: 1. A concise statement of factual issues to be decided at trial. II. A list of witnesses the party intends to call at trial along with a concise statement of their anticipated testimony. III. A list of all exhibits each party anticipates presenting at trial. IV. A statement of any legal issues each party anticipates being raised at trial along with copies of any cases which may be relevant to resolution of the stated issue. V. An estimate of the anticipated time needed for the party to present its case. Upon receipt and review of these memorandums, the Court will set a trial date for this case. By the Court, ?A -?' ?aly M. L. Ebert, Jr., J. no 80 :h Wd LZ NVW LUZ Advic,INOH 0IS?d 3a dG ]"1-14 n,3-1IJ Jeffrey P. Edmunds, Esquire Attorney for Plaintiff Michael S. Ferguson, Esquire Attorney for Defendant Court Administrator bas ROBERT DENNISON AND, IN THE COURT OF COMMON PLEAS MERRY E. DENNISON, CUMBERLAND COUNTY, PENNSYLVANIA HUSBAND AND WIFE, PLAINTIFFS V. CHARLES A. CORKLE, JR., DEFENDANT 04-1605 CIVIL ORDER OF COURT AND NOW, this 27th day of March, 2007, the non-jury trial in the above captioned case will be held on Monday, August 6, 2007 at 9:00 a.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, ?-1K M. L. Ebert, Jr., J. 4efFrey P. Edmunds, Esquire Attorney for Plaintiff I ?"asey G. Shore, Esquire Attorney for Defendant 1 .court Administrator* bas S 1 : i 11,111 l1- ON LOOZ A ROBERT DENNISON, and MERRY E. DENNISON, Husband And Wife Plaintiff, vs CHARLES A. CORKLE, JR., Defendant. TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 04-1605 Civil Term JURY TRIAL DEMANDED P R A E C I P E PLEASE REMOVE THE ABOVE-CAPTIONED MATTER FROM THE AUGUST TRIAL LIST. THIS IS WITH THE CONCURRENCE OF OPPOSING COUNSEL. Respectfully submitted, NEALON, GOVER & PERRY By l se G. Shore, Esquire Attor ey I.D. No. 85321 2411 North Front Street Harrisburg, PA 17110 Date: (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 201h day of Jam, 2007, 1 hereby certify that I have served the foregoing PRAECIPE TO REMOVE FROM TRIAL LIST on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire Carpenter & Edmunds 101 N. 11 th Street Sunbury, PA 17801-2432 Ca . Shore, Esquire _ - cam; - t Tl `.-_. - ` J f _ C7 . ? t,..-y _ ? f 1 PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case: (Check One) (x) for JURY trial at the next term of civil court. () for trial without a jury. (CAPTION OF CASE, entire caption must be state in full) (check one) ( ) Civil Action - Law (X) Appeal from Arbitration (other) The trial list will be called on August 21, 2007 and Trials commence on September 17. 2007 Pretrials will be held on August 29. 2007 ROBERT E. DENNISON, JR., and MERRY E. DENNISON, his wife, Vs. CHARLES A. CORKLE, JR., Plaintiff(s) Defendant(s) (Briefs are due 5 days pretrial.) (The party listing this case for trial shall provide forthwith a copy of the Praecipe to all counsel, pursuant to Local Rule 214.1.) No. 04-1605 Civil Term Indicate the attorney who will try case for the party who files this Praecipe: Casey G. Shore, Esquire Indicate trial counsel for other parties if known: Jeffrey P. Edmunds, Esquire This case is ready for trial. Date: 7JaD)O 7 NEALO GOV R PERRY By: Shore, Esquire A#w4 4-4. D. No. 85321 Attorney for: Charles A. Corkle, Jr. 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 20th day of Jam, 2007, 1 hereby certify that I have served the foregoing PRAECIPE FOR LISTING CASE FOR TRIAL on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Jeffrey P. Edmunds, Esquire Carpenter & Edmunds 101 N. 11 th Street Sunbury, PA 17801-2432 Cas y .Shore, Esquire /V IL M R Lrll? b O V f -- C? c" c~ CQ Ga }C1 ROBERT DENNISON and MERRY E. DENNISON, Husband and Wife, Plaintiffs V. CHARLES A. CORKLE, JR., Defendant #18 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-1605 CIVIL TERM JURY TRIAL DEMANDED IN RE: PRETRIAL CONFERENCE A pretrial conference was held on Wednesday, August 29, 2007, before the Honorable Edward E. Guido, Judge. Present for the Plaintiffs was Jeffrey P. Edmunds, Esquire, and present for the Defendant was Casey G. Shore, Esquire. The Defendant concedes liability. The only issue to be tried is the nature and extent of the damages. This case will take one day to try. There are no scheduling conflicts. There are no complicated legal issues. Settlement is unlikely. Edward E. Guido, J. Jeffrey P. Edmunds, Esquire Attorney for Plaintiffs Casey G. Shore, Esquire p - Attorney for Defendant a " Court Administrator m co srs C,,