HomeMy WebLinkAbout08-6734Stephen G. Held, Esquire
I.D.#72663
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000
Fax: (717) 233-3029
E-mail: Held .hhrlaw.com
ANGELA BOYER
39 Valley Road
Newville, PA 17241
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Attorneys for Plaintiff
No. -? l_IVs,
Civil Action - (XX) aw
( ) Equity
JURY TRIAL DEMANDED
LUKE SWEENEY
1109 Apple Drive - Apt. 6
versus Mechanicsburg, PA 17055
Plaintiff(s) &
Address(es)
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue A Writ of Summons in the above-captioned action.
Defendant(s) &
Address(es)
X Writ of Summons Shall be issued and forwarded to ( ) Attorney (XX)Sheriff
Stephen G. Held Esquire
1300 Linglestown Road
Harrisburg, PA 17110 Signatur of Attorney
(717) 238-2000 Supreme Court ID No. 72663
Name/Address/Telephone No.
of Attorney Date: November 11, 2008
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN
Date:
( ) Check here if reverse is used for additional information
PROTHON. - 55
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06734 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BOYER ANGELA
VS
SWEENEY LUKE
KENNETH E GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
SWEENEY LUKE the
DEFENDANT , at 0020:06 HOURS, on the 9th day of December-, 2008
at 1109 APPLE DRIVE
day
MECHANICSBURG, PA 17055
by handing to
LUKE SWEENEY DEFENDANT
a true and attested copy of WRIT OF SUMMONS
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Postage
So Answers:
18.00
32.40
'Mow
.00
10.00 R. Thomas Kline
.42
60 82 12/10/2008
HANDLER HENNING ROSENBERG
Sworn and Subscibed to
before me this
of
APT 6
By:
A. D.
- 1
STEPHEN L. BANKO, JR., ESQUIRE
Pa. Supreme Court I. D. No. 41727
MARGOLIS EDELSTEIN
3510 Trindle Road
Camp Hill, PA 17011
Telephone: (717) 760-7501
FAX: (717) 975-8124 Attorney for Defendant,
E-mail: sbankoAmargolisedelstein.com Luke Sweeney
IN THE COURT OF COMMON PLEAS
OF YORK COUNTY
ANGELA BOYER, [6-- CKET NO. 08-6734
Plaintiff
v. I CIVIL ACTION - LAW
LUKE SWEENEY,
Defendant JURY TRIAL DEMANDED
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Please issue Rule upon Plaintiff to file a Complaint within twenty (20) days from
service hereof or suffer judgment non pros.
Date
ZENSTP EDELSTEIN
1 By:
BANKO, JR.
Attorney for Defendant, Luke Sweeney
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all
counsel of record by placing the same in the United States mail at Camp Hill,
Pennsylvania, first-class postage prepaid, on the 15 day of
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2008, and addressed as follows:
Stephen G. Held, Esquire
Handler, Henning & Rosenberg, LLP
1300 Linglestown Road
Harrisburg, PA 17110
(Counsel for Plaintiff)
Roxanne K. Weller, Secretary
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IN THE COURT OF COMMON PLEAS
OF YORK COUNTY
ANGELA BOYER, DOCKET NO. 08-6734
Plaintiff
V. CIVIL ACTION - LAW
LUKE SWEENEY,
Defendant JURY TRIAL DEMANDED
RULE
TO THE PLAINTIFF:
You are hereby ordered and directed to file your Complaint against the Defendant
in the above-captioned matter within twenty (20) days of service of this Rule against you
or suffer judgment non Los.
Dated:
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STEPHEN L. BANKO, JR., ESQUIRE
Pa. Supreme Court 1. D. No. 41727
MARGOLIS EDELSTEIN
3510 Trindle Road
Camp Hill, PA 17011
Telephone: (717) 760-7501
FAX: (717) 975-8124 Attorney for Defendant
E-mail: sbanko margolisedelstein.com
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Kindly enter my appearance on behalf of Defendant, Luke Sweeney, in
the above-captioned matter.
Date: E
Attorney for Defendant
MA I DELSTEIN
ST -P? ? N . BANKO ,l R.
V( " -
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all
counsel of record by placing the same in the United States mail at Camp Hill,
Pennsylvania, first-class postage prepaid, on the day of ( c e-..Q? ,
2008, and addressed as follows:
Stephen G. Held, Esquire
Handler, Henning & Rosenberg, LLP
1300 Linglestown Road
Harrisburg, PA 17110
(Counsel for Plaintiff)
Roxanne K. Weller, Secretary
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4.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
ANGELA BOYER, DOCKET NO. 08-6734
Plaintiff
CIVIL ACTION - LAW
V.
LUKE SWEENEY, JURY TRIAL DEMANDED
Defendant
The undersigned hereby certifies that a true and correct copy of Rule to File Complaint of
Defendant, Luke Sweeney, was served upon the person and in the manner indicated
below:
Service by First Class Mail
Stephen G. Held, Esquire
Handler, Henning & Rosenberg, LLP
1300 Linglestown Road
Harrisburg, PA 17110
(Counsel for Plaintiff)
OLXS EDELSTEIN
Date: 5! G'
By:
Wpj
'?h L. Ba?ko, Jr., Esquire
Attorney No. 41727
Counsel for Defendant, Luke Sweeney
lk
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all
counsel of record by placing the same in the United States mail at Camp Hill,
Pennsylvania, first-class postage prepaid, on the ?±day of 2008, and addressed as follows:
Stephen G. Held, Esquire
Handler, Henning & Rosenberg, LLP
1300 Linglestown Road
Harrisburg, PA 17110
(Counsel for Plaintiff)
Roxanne K. Weller, Secretary
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Stephen G. Held, Esquire
I.D.#72663
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000 Attorneys for Plaintiffs
Fax : (717) 233-3029
E-mail: Heide-HHRLaw corn
ANGELA BOYER and JOSEPH : IN THE COURT OF COMMON PLEAS
BOYER, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. NO. 08-6734
LUKE SWEENEY, CIVIL ACTION - LAW
Defendant
COMPLAINT
AND NOW, come the Plaintiffs, Angela Boyer and Joseph Boyer, by and through
their attorney, HANDLER, HENNING & ROSENBERG, LLP, by Stephen G. Held, Esquire,
and make the within Complaint against the Defendant, Luke Sweeney, and aver as follows:
Plaintiff, Angela Boyer, is an adult individual currently residing at 39 Valley
Road, Newville, Cumberland County, Pennsylvania 17241.
2. Plaintiff, Joseph Boyer, is an adult individual currently residing at 39 Valley
Road, Newville, Cumberland County, Pennsylvania 17241.
3. Defendant, Luke Sweeney, is an adult individual currently residing at 1109
Apple Drive, Apartment 6, Mechanicsburg, Cumberland County, Pennsylvania 17055.
4. At all times material hereto, Plaintiff, Angela Boyer, was the owner and
operator of a 2004 Subaru Outback bearing Pennsylvania registration. (hereinafter
"Plaintiffs vehicle").
5. At all times material hereto, Defendant, Luke Sweeney, was the owner and
operator of a private passenger motor vehicle bearing Pennsylvania registration.
(hereinafter "Defendant's vehicle").
6. At all times material hereto, Plaintiff, Angela Boyer, was insured under a
Pennsylvania motor vehicle policy through State Farm Mutual Automobile Insurance
Company, with said policy providing for Full Tort status.
7. At all times material hereto, there were no adverse weather or road
conditions.
8. On or about November 18, 2006, at about 11:30 a.m., Plaintiff, Angela Boyer,
was lawfully stopped and/or stopping for a red traffic control device on High Street, in
Cumberland County, Pennsylvania.
9. At approximately the same time and place, Defendant, Luke Sweeney, was
traveling behind Plaintiffs vehicle, on High Street, in Cumberland County, Pennsylvania.
10. Suddenly and without warning, the vehicle being operated by Defendant,
Luke Sweeney, violently impacted the rear of Plaintiffs vehicle while Plaintiff, Angela
Boyer, was lawfully stopped and/or stopping for a red traffic control device.
11. As a direct and proximate result of the negligence of the Defendant, Luke
Sweeney, Plaintiff, Angela Boyer, sustained personal injuries, as set forth more specifically
below:
2
COUNT I - NEGLIGENCE
Angela Boyer v. Luke Sweeney
12. Plaintiff, Angela Boyer, incorporates and makes part of this Count,
paragraphs 1 through 11 above, as if the same were set forth fully below.
13. The occurrence of the aforementioned collision and the resultant injuries to
Plaintiff, Angela Boyer, are the direct and proximate result of the negligence, carelessness,
and/or recklessness of Defendant, Luke Sweeney, generally and more specifically as set
forth below:
(a) In failing to be reasonably vigilant to observe the road and traffic
conditions then and there existing;
(b) In failing to have due regard for the speed of the vehicles and the
traffic upon the road and the condition of the highway, in violation of
75 Pa. C.S.A. § 3310(a);
(c) In failing to operate his vehicle in such a manner that would allow him
to apply the brakes and stop before striking the rear of the vehicle in
front of him;
(d) In failing to operate his vehicle under proper and adequate control so
that he could have avoided striking Plaintiff's stopped vehicle in front
of him;
(e) In failing to properly regulate the speed of his vehicle so as to prevent
a rear-end collision;
3
(f) In failing to operate his vehicle at a speed and under such control so
as to be able to stop within the assured clear distance, in violation of
75 Pa. C.S.A. § 3361;
(g) In failing to operate his vehicle at a speed that was safe for existing
conditions, in violation of 75 Pa. C.S.A. § 3361;
(h) In following another vehicle more closely than is reasonable and
prudent;
(1) In failing to keep a proper lookout for vehicles lawfully stopped on
High Street, in Cumberland County, Pennsylvania;
(j} In failing to exercise reasonable care in the operation and control of
his vehicle, in violation of 75 Pa. C.S.A. § 3714;
(k) In failing to be continuously alert, in failing to perceive any warning of
danger that was reasonably likely to exist, and in failing to have his
vehicle under such control that injury to persons or property could be
avoided; and
(1) In otherwise driving his vehicle upon the roadway in a manner
endangering persons and property and in a manner with careless
disregard to the rights and safety of others in violation of the
Motor Vehicle Code of the Commonwealth of Pennsylvania.
14. As a direct and proximate result of the Defendant's negligence, Plaintiff,
Angela Boyer, sustained injuries, including, but not limited to a pain and symptoms to the
base of the neck and throughout the shoulders, as well as, upper back pain and lower back
pain (hips now from the lower back) pain down legs and arms with some numbness.
4
15. As a direct and proximate result of the Defendant's negligence, Plaintiff,
Angela Boyer, has suffered physical pain, discomfort, and mental anguish, and she will
continue to endure the same for an indefinite period of time in the future, to her physical,
emotional, and financial detriment and loss.
16. As a direct and proximate result of the Defendant's negligence, Plaintiff,
Angela Boyer, has been compelled, in order to effect a cure for the aforesaid injuries, to
spend money for medicine and/or medical attention, and will be required to expend money
for the same purposes in the future, to her detriment and loss.
17. As a direct and proximate result of the Defendant's negligence, Plaintiff,
Angela Boyer, has been, and probably will in the future be, hindered from attending to her
daily duties, to her detriment, loss, humiliation, and embarrassment.
18. As a direct and proximate result of the Defendant's negligence, Plaintiff,
Angela Boyer, has suffered a loss of life's pleasures, and will continue to endure the same
in the future, to her detriment and loss.
WHEREFORE, Plaintiff, Angela Boyer, seeks damages from Defendant, Luke
Sweeney, in an amount in excess of the compulsory arbitration limits of Cumberland
County, exclusive of interest and costs.
5
COUNT II - LOSS OF CONSORTIUM
Joseph Boxer v. Luke Sweeney
19. Plaintiff, Joseph Boyer incorporates and makes partof this Count paragraphs
1 through 18 above, as if the same were set forth fully below.
20. At all times material to this action, Plaintiffs, Angela Boyer and Joseph Boyer,
were lawfully married as husband and wife. (Also the children not being able to care, teach
or play with them); i.e., teaching daughter to jump rope, etc. They have also greatly
suffered.
21. As a direct and proximate result of Defendant's negligence, the Plaintiff,
Joseph Boyer, has suffered a loss of consortium, society, and comfort from his wife,
Angela Boyer, and he will continue to suffer a similar loss in the future.
22. As a direct and proximate result of Defendant's negligence, the Plaintiff,
Joseph Boyer, has been compelled, in order to effect a cure for his wife's injuries, to
expend money for medicine and medical attention and will be required to expend more for
the same purposes in the future, to his detriment and loss.
6
WHEREFORE, Plaintiff, Joseph Boyer, seeks damages from the Defendant, Luke
Sweeney, in an amount in excess of the compulsory arbitration limits of Cumberland
County exclusive of interest and costs.
Date:
Respectfully submitted,
HANDLER, HENNING & ROSENBERG, LLP
By:
S Held, Esquire
1. D. # 2663
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Attorneys for Plaintiffs
7
VERIFICATION
THE UNDERSIGNED hereby verifies that the statements in the foregoing
document are based on information that was gathered by counsel in preparation of this
lawsuit. The language of the above-named document is of counsel and not my own. I
have read the said document and, to the extent that it is based on information that I
gave to counsel, it is true and correct to the best of my knowledge, information, and
belief. To the extent that the contents of the said document is that of counsel, I have
relied upon my counsel in preparing this Verification.
THE UNDERSIGNED also understands that the statements therein are made
subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn
falsification to authorities.
Date: /' i & .0'::7
VERIFICATION
THE UNDERSIGNED hereby verifies that the statements in the foregoing
document are based on information that was gathered by counsel in preparation of this
lawsuit. The language of the above-named document is of counsel and not my own. I
have read the said document and, to the extent that it is based on information that I
gave to counsel, it is true and correct to the best of my knowledge, information, and
belief. To the extent that the contents of the said document is that of counsel, I have
relied upon my counsel in preparing this Verification.
THE UNDERSIGNED also understands that the statements therein are made
subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn
falsification to authorities.
Date: /--/6 -O
seph Boyer
Stephen G. Held, Esquire
I.D.#72663
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000
Fax : (717) 233-3029
E-mail: Held@HHRLaw.com
ANGELA BOYER and JOSEPH
BOYER, her husband,
Plaintiffs
V.
LUKE SWEENEY,
Defendant
Attorneys for Plaintiffs
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-6734
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
On February 9, 2009, 1 hereby certify that a true and correct copy of Plaintiffs' Complaint
was served upon the following by depositing same in the United States Mail, in Harrisburg,
Pennsylvania:
Mr. Stephen L. Banko, Esq.
Margolis Edelstein
3510 Trindle Road
Camp Hill, PA 17011
HANDLER, HENNING 8, ROSENBERG, LLP
Dated: 2/9/09
Step en ACI
I. D. #72663
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Attorney for Plaintiffs
t
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
ANGELA BOYER TERM,
CUMBERLAND
-VS- CASE NO: 08-6734
LUKE SWEENEY
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of STEPHEN L. BANKO, JR., ES
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: 02/23/2009
MCS on behalf of
STEPHEN L. BANKO, JR., ESQ.
Attorney for DEFENDANT
R2.06 133-H DE11-0853950 10666-LO1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
ANGELA BOYER
-VS-
LUKE SWEENEY
COURT OF COMMON PLEAS
TERM,
CASE NO: 08-6734
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
MECHANICSBURG FAMILY PRACTICE MEDICAL RECORDS
GATEWAY HEALTH PLAN INSURANCE
TO: STEVEN HELD, ESQ., PLAINTIFF COUNSEL
MCS on behalf of STEPHEN L. BANKO, JR., ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 01/30/2009
CC: STEPHEN L. BANKO, JR., ESQ. - 63000.4-00092
STEVEN HELD, ESQ.
HANDLER, HENNING, ET AL
1300 LINGLESTOWN ROAD
SUITE 2
HARISBURG, PA 17110
MCS on behalf of
STEPHEN L. BANKO, JR., ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
R1.80S 133-H DE02-0465372 10666-CO1
ANGELA BOYER
VS.
LUKE SWEENEY
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
File No. 08-6734
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO
Custodian of Records for ME ANICSB 1RG FAMILY PRACTICE
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SER ATTACHED RIDER****
at The M . Ca=. Ic•, 1601 Market Street Suite 800?P ilad .pia, PA 1 103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: STEPHEN L. BANKO. JR.. ESQ.
ADDRESS: 3510 TRINDLE ROAD
CAMP HILL, PA 17011
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Deiendant
BY THE COURT:
FHB 2 3 2009
Dater ?.?
Seal of the Court
/f/ ?4' j /
Prothonotary/Clerk, Civil Division ,
Deputy ?' `?
10666-01
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
MECHANICSBURG FAMILY PRACTICE
122 S. FILBERT STREET
MECHANICSBURG, PA 17055
RE: 10666
ANGELA BOYER
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : ANGELA BOYER
39 VALLEY ROAD, NEWVILLE, PA 17241
Social Security #: XXX-XX-3194
Date of Birth: 09-19-1974
R1.80S 133-H SU10-0770548 10666-LO1
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
ANGELA BOYER
LUKE SWEENEY
-VS-
COURT OF COMMON PLEAS
TERM,
CUMBERLAND
CASE NO: 08-6734
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of STEPHEN L. BANKO, JR., ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 02/23/2009
MCS on behalf of
STEPHEN L. BANKO, JR., ESQ.
Attorney for DEFENDANT
R2.06 133-H DE11-0853954 10 6 6 6 - L02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ANGELA BOYER
VS.
LUKE SWEENEY
File No. 08-6734
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 40".22
TO:
Custodian of Records for GATEWAY HEALTH PLAN
(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 CGroun nc , 160, Market Street Site 800, P ilade pj ia„ PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: STEPHEN L. BANKO. JR.. ESOP,
ADDRESS: 3510 IND .. ROAD
CAMP HILT,, PA 17011
TELEPHONE: (215.) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
FEB 2 3 2009
Date: _ 7,;, U j
Seal of the Court
BY THE COURT:
Prothonotary/Clerk, Civil Divisi n
Depu
10666-02
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
GATEWAY HEALTH PLAN
P.O. BOX 11-718
ALBANY, NY 12211
RE: 10666
ANGELA BOYER
Prior approval is required for fees in excess of $150.00 for
hospitals, $100.00 for all other providers.
POLICY #: 22183147
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 : ANGELA BOYER
39 VALLEY ROAD, NEWVILLE, PA 17241
Social Security #: XXX-XX-3194
Date of Birth: 09-19-1974
Date of Loss: 11/18/2006
R1-80S 133-H SU10-0770550 10666-LO2
G.!
CIO
i
Joseph R. D'Annunzio, Esquire
I.D. No. 23384
4309 Linglestown Road, Suite 211 Attorney for Defendant,
Harrisburg, PA 17112 Luke Sweeney
717-901-5002
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ANGELA BOYER and
JOSEPH BOYER, Her Husband
Plaintiffs
V.
LUKE SWEENEY,
Defendant
NO. 08-6734
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: Angela Boyer and Joseph Boyer, Plaintiffs
c/o Stephen G. Held, Esquire
1300 Linglestown Road
Harrisburg, PA 17110
Attorneys for Plaintiffs
You are hereby notified to file a written response to the enclosed New
Matter within twenty (20) days from service hereof or a default judgment may be
entered against you.
LAW OFFICE OF
JOSEPH R. D'ANNUNZIO
Date:-??. 13, 1Av r By: 2_ '?J'
Joseph R. D'Annu zio, Esquire
Attorney for Defendant,
Luke Sweeney
Joseph R. D'Annunzio, Esquire
I.D. No. 23384
4309 Lingiestown Road, Suite 211 Attorney for Defendant,
Harrisburg, PA 17112 Luke Sweeney
717-901-5002
IN THE COURT OF COMMON PLEAS OF
LEBANON COUNTY, PENNSYLVANIA
ANGELA BOYER and
JOSEPH BOYER, Her Husband
Plaintiffs
NO. 08-6734
V.
CIVIL ACTION - LAW
LUKE SWEENEY, JURY TRIAL DEMANDED
Defendant
ANSWER AND NEW MATTER OF DEFENDANT,
LUKE SWEENEY. TO PLAINTIFFS' COMPLAINT
1. and 2. Admitted only that the Plaintiffs are Angela Boyer and
Joseph Boyer who are adult individuals. The address of the Plaintiffs is unknown
to the answering Defendant and strict proof is demanded.
3. Admitted only that the Defendant is Luke Sweeney, an adult
individual who at the time of this accident resided at 1109 Apple Drive, Apartment
6 in Mechanicsburg, Pennsylvania.
4. Admitted.
5. Admitted.
6. After reasonable investigation the Defendant is without knowledge
or information sufficient to form a belief as to the averments set forth in this
paragraph. Accordingly, they are deemed denied and strict proof is demanded.
I l
7. Denied as a conclusion of law to which no responsive pleading is
required.
8. Denied as a conclusion of law to which no responsive pleading is
required.
9. Admitted.
10. Admitted only that the Defendant's vehicle came into a slight and
insignificant contact with the Plaintiffs vehicle. The remaining averments are
denied as conclusions of law.
11. Denied. It is denied that the collision was due solely to the
negligence of the Defendant and that it was not the fault in any manner
whatsoever of the Plaintiff, Angela Boyer. To the contrary, it is averred that the
Plaintiff, Angela Boyer, was negligent in her failure to operate her motor vehicle
in a reasonable and prudent manner and at a rate of speed that was prudent
under the circumstances which caused her to make a sudden and unexpected
stop. Accordingly, it is averred that the negligence of the Plaintiff, Angela Boyer,
as aforesaid, was a substantial factor in bringing about the collision aforesaid.
The remaining averments are denied as conclusions of law to which no
responsive pleading is required.
COUNTI
ANGELA BOYER v. LUKE SWEENEY
12. The answers to paragraphs 1 through 11 are incorporated by
reference as if fully set forth herein.
13. Denied. The averments set forth in these paragraphs are denied
as conclusions of law to which no responsive pleading is required.
14. through 18. Denied that the Defendant was negligent or that the
Plaintiff sustained any injury as a result of the negligence of the Defendant. To
the contrary, the Defendant exercised all due and reasonable care in the
operation of his motor vehicle. After reasonable investigation the Defendant is
without sufficient knowledge or information to form a belief as to the truth of the
averments regarding injuries or damages. Accordingly, the averments are
deemed denied and strict proof is demanded.
WHEREFORE, Defendant, Luke Sweeney, demands that judgment be
entered in his favor.
COUNT II
JOSEPH BOYER v. LUKE SWEENEY
19. The answers to paragraphs 1 through 18 are incorporated by
reference as if fully set forth herein.
20. After reasonable investigation the Defendant is without knowledge
or information sufficient to form a belief as to the truth of the averments set forth
in this paragraph regarding the relationship of the Plaintiffs. Accordingly, the
averments are deemed denied and strict proof is demanded.
21. and 22. It is denied that the Defendant was negligent or that his
conduct in any way caused any injury to the Plaintiff, Joseph Boyer. To the
contrary, the Defendant operated his motor vehicle while exercising due and
reasonable care. After reasonable investigation the Defendant is without
knowledge or information sufficient to form a belief as to the truth of the
averments set forth in these paragraphs regarding injuries and damages.
Accordingly, the averments are deemed denied and strict proof is demanded.
WHEREFORE, Defendant, Luke Sweeney, demands that judgment be
entered in his favor.
NEW MATTER
23. At all times relevant to this Complaint and cause of action the
Plaintiff, Angela Boyer, was operating her motor vehicle while traveling on High
Street, a public thoroughfare in Cumberland County, Pennsylvania.
24. At the time she was operating the motor vehicle, the Plaintiff came
to a sudden and unexpected stop on the highway when there was no good
reason for her to do so, causing a collision.
25. The collision that is set forth in the Plaintiffs' Complaint was directly
and proximately caused by the negligence of the Plaintiff, Angela Boyer, said
negligence consisting in the following:
A. The Plaintiff operated her motor vehicle in a careless and
negligent fashion without regard for the position of other
vehicles on the roadway;
B. The Plaintiff operated her motor vehicle in an inattentive and
careless manner and without due regard for the rights, safety
and position of the Defendant on the highway;
I I-
C. The Plaintiff operated her motor vehicle in a careless,
negligent, and reckless manner and she was inattentive in
her driving which caused the collision with the Defendant's
vehicle.
26. The direct and proximate cause of the collision and the injuries
allegedly sustained by the Plaintiffs was the negligence of the Plaintiff, Angela
Boyer, in her operation of the motor vehicle.
27. The claims of the Plaintiffs are barred by the contributory
negligence of the Plaintiff, Angela Boyer, such negligence being the proximate
cause and the substantial factor in the collision aforesaid.
28. The claims of the Plaintiffs are barred and/or limited by the
comparative negligence of Plaintiff, Angela Boyer in the operation of her motor
vehicle, said negligence being a substantial factor in the cause of the collision
and resulting injuries as claimed by the Plaintiffs.
29. At all times relevant to this Complaint and cause of action, the
Plaintiff, Angela Boyer, voluntarily assumed the risk of the conduct of her
operation of her motor vehicle and so is barred by her voluntary assumption of
the risk of the conduct.
30. At all times relevant to this Complaint and cause of action the
Plaintiffs were covered by a policy of motor vehicle insurance in which they
elected the Limited Tort option of coverage.
31. The Plaintiffs' claims for non-economic loss are barred because
they elected the Limited Tort option of coverage and they have failed to establish
that the Plaintiff sustained a serious injury which would pierce the Limited Tort
threshold for recovery.
32. The Plaintiffs' claims for economic loss are barred and limited by
the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law.
33. At all times relevant to this Complaint and cause of action, the
Defendant, Luke Sweeney, operated his motor vehicle with all due and
reasonable care and so is not responsible to the Plaintiffs for their injuries and
damages.
WHEREFORE, Defendant, Luke Sweeney, demands that judgment be
entered in his favor.
LAW OFFICE OF
JOSEPH R. D'ANNUNZIO
Date: By: -?.-
Joseph R. D'Annunzio, Esquire
Attorney for Defendant,
Luke Sweeney
I
VERIFICATION
I, Luke Sweeney, hereby states that he is the Defendant in this action, and
verifies that the statements made in the foregoing document are true and correct
to the best of his knowledge, information and belief. The undersigned
understands that the statements therein are made subject to the penalties of 18
Pa. C.S.A. 4904 relating to unsworn falsification to authorities.
Date: -1 - o?
LUKE S NE
CERTIFICATE OF SERVICE
I do hereby certify that on this 13t?- day of
2009, 1 caused a true and correct copy of the foregoing Answer to Plaintiffs'
Complaint to be served upon the following persons listed below via first class
United States mail, postage prepaid:
Stephen G. Held, Esquire
1300 Linglestown Road
Harrisburg, PA 17110
Attorney for Plaintiffs
BY:
R a ne Weller, Secretary
.Y _rt CA?
Joseph R. D'Annunzio, Esquire
I.D. No. 23384
4309 Linglestown Road, Suite 211 Attorney for Defendant,
Harrisburg, PA 17112 Luke Sweeney
717-901-5002
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ANGELA BOYER and
JOSEPH BOYER, Her Husband
Plaintiffs
NO. 08-6734
V.
LUKE SWEENEY,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Defendant, Luke Sweeney, in the
above-captioned matter.
LAW OFFICE OF JOSEPH R.
D'ANNUNZIO
Date: /nr, 2o?'Y BY: "4?vi /J.
Joseph R. D'Annunzio, Esquire
Attorney for Defendant
" . ..,.,
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a true and correct copy of the foregoing
on all counsel of record by placing the same in the United States mail at
Harrisburg, Pennsylvania, first-class postage prepaid, on the 19h day of March,
2009, and addressed as follows:
Stephen G. Held, Esq.
Handler, Henning & Rosenberg
1300 Linglestown Road
Harrisburg, PA 17110
Attorney for Plaintiff
By: wcw'
Roxanne Weller, Secretary
C-n
w
t -•a
STEPHEN L. SANKO, JR., ESQUIRE
Pa. Supreme Court 1. D. No. 41727
MARGOLIS EDELSTEIN
3510 Trindle Road
Camp Hill, PA 17011
Telephone: (717) 760-7501
FAX: (717) 975-8124
E-mail: shank ftmaraolisedelstein.com
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
ANGELA BOYER, DOCKET NO. 08-6734
Plaintiff
V. CIVIL ACTION - LAW
LUKE iSWEENEY,
Defendant JURY TRIAL DEMANDED
0 - 0
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Kindly withdraw my appearance on behalf of Defendant, Luke Sweeney, in the
above-captioned matter.
Date: Z, ! Z g10I
MA LIS
By: EDELSTEiN
ST EN L. BANKO, JR.
t i
STEPHEN L. BANKO, JR., ESQUIRE
Pa. Supreme Court I. D. No. 41727
MARGOLIS EDELSTEIN
3510 Trindle Road
Camp Hill, PA 17011
Telephone: (717) 760-7501
FAX: (717) 975-8124
E-mail: sbankg@mara!Rlisedeistein.com
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
ANGELA BOYER, DOCKET NO. 08-6734
Plaintiff
V. -CIVIL ACTION - LAW
LUKE SWEENEY,
Defendant JURY TRIAL DEMANDED
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Kindly withdraw my appearance on behalf of Defendant, Luke Sweeney, in the
above-captioned matter.
MAI' t0gLIS EDELSTEIN
Date: By:
ST P EN L. BANKO, JR.
rya
-ri
._. r j rcl
CA
C,)
Stephen G. Held, Esquire
I.D.#72663
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000 Attorneys for Plaintiffs
Fax : (717) 233-3029
ANGELA BOYER and JOSEPH : IN THE COURT OF COMMON PLEAS
BOYER, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. NO. 08-6734
LUKE SWEENEY, CIVIL ACTION - LAW
Defendant
PLAINTIFFS' REPLY TO NEW MATTER
AND NOW, come the Plaintiffs, Angela Boyer and Joseph Boyer, by and through
their attorney, HANDLER, HENNING & ROSENBERG, LLP, by Stephen G. Held, Esquire,
and make the within Plaintiffs' Reply to New Matter and aver as follows:
23. Admitted.
24. Denied, as stated. It is admitted that Plaintiff was operating a motor vehicle.
She came to a stop and was hit from the rear. However, the remainder of
her statements are denied as categorized in this paragraph.
25. This averment is a conclusion of law to which no responsive pleading is
required. To the extent that this averment may be deemed factual, it is
i
hereby denied. By way of amplification, it is denied that Plaintiff was
negligent and it denied specifically that Defendant operated her motor
vehicle in a careless and negligent fashion, that Plaintiff operated her motor
vehicle in an inattentive and careless manner and that Plaintiff operated her
motor vehicle in a careless, negligent and reckless manner and that she was
unattentative.
26. This averment is a conclusion of law to which no responsive pleading is
required. To the extent the averment may be deemed factual, it is hereby
denied. By way of amplification, it is denied that Plaintiff was negligent.
27. This averment is a conclusion of law to which no responsive pleading is
required. To the extent the averment may be deemed factual, it is hereby
denied. By way of amplification, it is denied that Plaintiff was negligent.
28. This averment is a conclusion of law to which no responsive pleading is
required. To the extent the averment may be deemed factual, it is hereby
denied. By way of amplification, it is denied that Plaintiff was negligent.
29. This averment is a conclusion of law to which no responsive pleading is
required. To the extent this averment may be deemed factual; it is hereby
denied. By way of amplification, it is hereby denied that Angela Boyer
voluntarily assumed the risk of any of her injuries.
30. This averment is a conclusion of law to which no responsive pleading is
required. To the extent this averment may be deemed factual; it is hereby
denied. By way of amplification, it is denied that Plaintiff hod the limited tort
option.
2
31. This averment is a conclusion of law to which no responsive pleading is
required. To the extent this averment may be deemed factual; it is hereby
denied. By way of amplification, it is denied that Plaintiff had the limited tort
option.
32. This averment of this paragraph is a conclusion of law to which no
responsive pleading is required. To the extent this averment may be
deemed factual, it is hereby denied. By way of amplification, Plaintiffs'
claims for economic loss are neither barred nor limited by the provisions of
the Pennsylvania Motor Vehicle Responsibility Law.
33. This averment is a conclusion of law to which no responsive pleading is
required. To the extent this averment may be deemed factual; it is hereby
denied. By way of amplification, it is denied that all times relevant to this
complaint and cause of action, the Defendant, Luke Sweeney, operated his
motor vehicle will all do and reasonable care.
WHEREFORE, Plaintiffs' demand judgment in their favor against Defendants.
Respectfully submitted,
Date:
HANDLER, HENNING & ROSENBERG, LLP
By:
e en eld, Esquire
I . D. #72663
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Attorneys for Plaintiffs
3
i
Stephen G. Held, Esquire
I.D.#72663
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000 Attorneys for Plaintiffs
Fax : (717) 233-3029
E-mail: Held@HHRLaw.com
ANGELA BOYER and JOSEPH : IN THE COURT OF COMMON PLEAS
BOYER, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. : NO. 08-6734
LUKE SWEENEY, CIVIL ACTION - LAW
Defendant
CERTIFICATE OF SERVICE
On this day March, 2009, 1 hereby certify that a true and correct copy of Plaintiffs'
Reply to New Matter was served upon the following by depositing same in the United States
Mail, in Harrisburg, Pennsylvania:
Joseph R. D'Annunzio, Esquire
LAW OFFICES OF JOSEPH R. D'ANNUZIO
4309 Linglestown Road,Suite 211
Harrisburg, PA 17112
HANDLER, H ING & ROSENBERG, LLP
Dated: 3/24/09
Stephe eld
Fn
-Ti -1
-
3
r-n
IN THE COURT OF COMMON PJ.EAS OF CUMBERLAND COUNTY
BOYER
Vs.
NO. 0806734P
SWEENEY
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 JOSEPH R D'ANNUNZIO, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 09/30/09
JOSEPH R D'ANNUNZIO, ESQUIRE
4309 LINGLESTOWN RD
SUITE 211
HARRISBURG, PA 17112
717-901-5002
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215) 335-3581
By: Eileen Porowicz
MLR File #: M367282
COMKNWFALTH OF PENNSYLVANIA
COUNTY OF CUMB RIB
BOYER
Vs. Fi le No.
SWEENEY
0806734P
SUBPOENA TO PRODUCE DOCIA•ENTS OR THIhM
FOR DISCOVERY PURSUANT TO RULE 4009.22
HERSHEY MED CENTER, 500 UNIVERSITY DR, HERSHEY PA 17033
TO: ATTN: MEDICAL RECORDS DEPT
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following do0-nmt5 oftn%:?? D IAWMEND-1-24
at _
MEDICAL LEGAL REPRODUCTIONS, TNe, 4940 BISSIPON ST., Zj1XTTWA , ]?A
(Address)
You may deliver or mail legible copies of the documents or produce things requested b?
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 docunents or things required by this subpoena within twenty
(20) days after its service, the party serving thin subpoena may seek a court orde•
ompe l l i ng you to coup l y with it.
THIS SUBPOENA WAS ISSUED AT THE REGMST OF THE FOLLOWING PERSON:
JOSEPH R D"ANNUNZIO, E Q
NAME:
ADDRESS: 4309 LINGLESTOWN RD
HARRISBURG, PA 17112
TELEPHONE:
SUPREME COURT ID #
ATTORNEY FOR:
M367282-01
DEFENDANT
DATE: __? Z/ a0-09
Seal of the Court
BY THE COURT:
s Lau, W.
T' Prothonotary/C1 , Civil Division
Deputy
(Eff. 7/97)
ADDENDUM
TO SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR: HERSHEY MED CENTER
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray reports, out-patient records physical
therapy records, and any other information pertaining to:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ANY AND ALL RECORDS/TESTS.
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature for
HERSHEY MED CENTER
CUMBERLAND
M367282-01
* * * SIGN AND RETURN THIS PAGE * * *
rr*&9V4WEALTH OF PENNSYLVANIA
OOuNry OF cuKBERLAW
BOYER
Vs. File No. 0806734P
SWEENEY
• ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PROOIJCE DOCUMENTS OR TH I NOS
FOR DISOOMERY PURSUANT TO RULE 4009.22
HERSHEY MED CENTER-X, 500 UNIVERSITY DR, HERSHEY PA 17033
TO: ATTN: RADIOLOGY DEPT
(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 cwSkgng??
at _
MEDICAL LEGAL REFRODUC1102118, Ne, 494e BmssTeN ST., PzxLA
(Address)
You may deliver or mail legible copies of the documents or produce things requested b?
this subpoena, together with the certificate of compliance, to the party making thi:
request at the address listed above. You have the right to seek in advance the rea.onable
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within t%,enty
(20) days after its service, the party serving thin subpoena may seek a court order
cxxr pe l ling you to cortp 1 y with it.
THIS SUBPOENA WAS ISSUED AT THE RECAJEST OF THE FOLLOWING PERSON:
NAME: JOSEPH R D'ANNUNZIO, ESQ
ADDRESS: 4309 LINGLESTOWN RD
HARRISBURG, PA 17112
TELEPHONE : 2
SUPREME OOURT ID #
ATTORNEY FOR:
DEFENDANT
M367282-02
DATE : 41 .20-&9'
Seal of the Court
BY THE COURT:
T? Prothonotary/C ark, Civil Division
-- Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
BOYER
Vs.
SWEENEY
No. 0806734P
CUSTODIAN OF RECORDS FOR: HERSHEY MED CENTER-X
ANY AND ALL FILMS.
PERTAINING TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ORIGINAL X-RAYS REQUESTED
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ J RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ J NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X.-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
HERSHEY MED CENTER-X
CUMBERLAND
M367282-02
* * * SIGN AND RETURN THIS PAGE * * *
ppwwwWFALTH OF PENNSYLVANIA
COUNTY OF Q KBEPIAM
BOYER
Vs.
SWEENEY
0806734P
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
WALNUT BOTTOM RADIOLOGY, 850 WALNUT BOTTOM RD, CARLISLE PA 17013
T0:
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following docLnents oS n%TT AGH'n A nt'E'SW
at _
MEDICAL LEGAL • • PHILA., FA --
(Address)
You may deliver or mail legible copies of the documents or produce things requester4 h?
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 thin subpoena may seek a court ordei-
cxxme l l i ng you to ca, l y with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: JOSEPH R D'ANNUNZIO, ESQ
ADDRESS :
4309 LINGLESTOWN RD
HARRISBURG PA 17112
TELEPHONE: ,.,12
SUPREME COURT ID #
ATTORNEY FOR: _
DEFENDANT
M367282-03
DATE : Ts ,lam 14 21?v 9
Seal of the Court
BY THE OOURT :
Prothonotary/ erk, civil Division
Deputy
File No.
(Eff. 7/97)
ADDENDUM TO
SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR : WALNUT BOTTOM RADIOLOGY
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ANY AND ALL RECORDS, TESTS AND FILMS.
ORIGINAL X-RAYS REQUESTED
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature for
WALNUT BOTTOM RADIOLOGY
CUMBERLAND
M367282-03
* * * SIGN AND RETURN THIS PAGE * * *
rrV&TW i EALTH 'OF PENNSYLVANIA
cowry oFaI49MIAND
BOYER
Vs.
SWEENEY
Fi le No. 0806734P
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
GILDEA CHIRO, 806 HOLLY PK, MT HOLLY SPRINGS PA 17065
(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 oSLLn?CR+$->4$NmTA4
at _
MEDICAL LEG PA
(Address)
You may deliver or mail legible copies of the documents or produce things requested t?
this subpoena, together wit!j the certificate of ccrtpliance, to the party making thiZ
request at the address listed above. You have the right to seek in advance the rea.onabir
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 thin subpoena may seek a court ordei-
cxmpe l l i ng you to cmp 1 y with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
Nom, JOSEPH R D'ANNUNZIO, ESQ
ADDRESS : 4309 L INGLESTOWN RD
HARRISBURG. PA 17112
TELEPHONE:
- 3 3 5--32-12-
SUPREIIE OOURT I D
ATTORNEY FOR:
DEFENDANT
M367282-04
DATE : ,
J
<.fI I/ 409
Seal of the Court
BY THE UOURT :
Prothonotary/C erk, Civil Division
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR: GILDEA CHIRO
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ANY AND ALL RECORDS, TESTS AND FILMS.
ORIGINAL X-RAYS REQUESTED
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( } RECORDS / XRAYS have been destroyed
Date Authorized signature or
GILDEA CHIRO
CUMBERLAND
M367282-04
* * * SIGN AND RETURN THIS PAGE * * *
co#AKora1F7LLTR OF PENNSYLVANIA
QJ[ ffy OF-CUMBERLAM
BOYER
Vs. ,
SWEENEY
Fi IS No. 0806734P
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE DOCUhENTS OR THIN(38
FOR DISCOVERY PURSUANT TO RULE 4009.22
SADLER HEALTH CTR, 100 N HANOVER ST, CARLISLE PA 17013
TO:
(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 orS "SA nE -A4
a?
at
MEDICAL LEGAL R r ST., i7 Z---
(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 thin subpoena may seek a court ordei-
am pe l l i ng you to oonp l y with it.
THIS SUBPOENA WAS ISSUED AT THE REM EST OF THE FOLLOWING PERSON:
NAB: JOSEPH R D'ANNUNZIO, ESQ
ADDRESS:
4309 LINGLESTOWN RD
HARRTSBURC`, PA 17112
TELEPHONE: r n?
3UPREW COURT I D # - - - - - --
1TTORNEY FOR: _
DEFENDANT
367282-05
4TE: ,L . 14 2OvS
Seal of the Court
BY THE COURT:
51 LT," " /L A e-
Prothonotary/CYerk, Civil Division
Deputy
ADDENDUM
BOYER
Vs.
SWEENEY
No. 0806734P
CUSTODIAN OF RECORDS FOR: SADLER HEALTH CTR
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ANY AND ALL RECORDS, TESTS AND FILMS.
ORIGINAL X-RAYS REQUESTED
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
SADLER HEALTH CTR
CUMBERLAND
M367282-05
TO SUBPOENA
* * * SIGN AND RETURN THIS PAGE * * *
COMMONWEALTH OF ?YLVANIA
COUN rY OF CLDCBERIAND
BOYER
Vs. ,
SWEENEY
File No. 0806734P
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE D=1 ENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
CARLISLE REG MED CTR, 417 VILLAGE DR STE 4, CARLISLE PA 17013
TO:
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 orsk9n9ATTACHED DETSM-1-14W
at _
MEDICAL LEGAL . ' EkA ---
(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 thi:
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 thin subpoena may seek a court orde:-
am pe l l i ng you to carp 1 y with it.
THIS SUBPOENA WAS ISSUED AT THE REMEST OF THE FOLLOWING PERSON:
NAME: JOSEPH R D'ANNUNZIO, ESQ
ADDRESS:
4309 LINGLESTOWN RD
HARRISBURG, PA 17112
TELEPHONE : , -212
SUPREME COURT ID #
ATTORNEY FOR:
M367282-06
DEFENDANT
DATE : /I I br, 9
Seal of the Court
BY THE COURT:
Prothonotary/C erk, Civil Division
Deputy
(Eff. 7/9T)
ADDENDUM TO SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR : CARLISLE REG MED CTR
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ORIGINAL X-RAYS REQUESTED
ANY AND ALL RECORDS, TEST AND FILMS.
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
to Authorized signature or
CARLISLE REG MED CTR
CUMBERLAND
M367282-06
* * * SIGN AND RETURN THIS PAGE * * *
rrs@K iwmLTR of PENNSYLVANIA
couNry OF aDOMMIAND
BOYER
Vs.
SWEENEY
Fi le No. 0806734P
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
SPINAL IMAGING, PO BOX 1200, S EASTON MA 02375
TO:
(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 OS99NATI -DENDI-1-M
at
MEDICAL • • PHILA., PA
- ---
(Address)
You may deliver or mail legible copies of the documents or produce things requested b?
this subpoena, together with the certificate of compliance, to the party making thi:
request at the address listed above. You have the right to seek in advance the rea.onable
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 thi, subpoena may seek a court orde;1
cxnpe l l i ng you to carte l y with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAB: JOSEPH R D'ANNuNZIO, ESQ
ADDRESS : 4309 LINGLESTOWN RD
HARRISBURG, PA 17112
TELEPHONE : , 5 ,' .,
SUPREME COURT ID #
ATTORNEY FOR:
M367282-07
DEFENDANT
DATE : i/ d c?v y -A 71
Seal of the Court
BY THE COURT:
Prothonotary/C1 k, Civil Division
Deputy
(Eff. 7/97)
ADDENDUM TO
SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR : SPINAL IMAGING
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ANY AND ALL RECORDS, TEST AND FILMS.
ORIGINAL X-RAYS REQUESTED
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
SPINAL IMAGING
CUMBERLAND
M367282-07
* * * SIGN AND RETURN THIS PAGE * * *
OF PENNSYLVANIA
COUNTY OF QPGRILAND
BOYER
Vs. Fi Is No.
SWEENEY
0806734P
MEDICAL BILLING REQUESTED
TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
PINNACLE HEALTH MED SYS, PO BOX 2253, HARRISBURG PA 17105
TO: ATTN: MEDICAL RECORDS DEPT
(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 ors ADDENDUM
at
-
MEDICAL LEGAL REPRODUCTIONS-77 . •, F*
(Address)
You may deliver or mail legible copies of the documents or produce things requested h?
this subpoena, together with the certificate of compliance, to the party making thiE
request at the address listed above. You have the right to seek in advance the rea.onablE
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 thi, subpoena may seek a court orde
rxmpe l l i ng you to cane 1 y with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: JOSEPH R D'ANNUNZIO, ESQ
ADDRESS:
4309 LINGLESTOWN RD
14ARRT9BURG, PA 17112
TELEPHONE : 3-35- 3212-
SUPREME COURT ID #
ATTORNEY FOR: _
DEFENDANT
M367282-08
DATE : LL',.J" -, / r .2 ov rf
Seal of the Court
BY THE COURT:
Prothonotary/C1 , Civil Division
?r Deputy
(Eff. 7/97)
ADDENDUM TO
SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH MED SYS
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray reports, out-patient records physical
therapy records, and any other information pertaining to:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
MEDICAL BILLING REQUESTED
TO INCLUDE ALL RECORDS FROM ALL PROVIDERS IN THIS HEALTH SYSTEM
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ l RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
PINNACLE HEALTH MED SYS
CUMBERLAND
M367282-08
* * * SIGN AND RETURN THIS PAGE
CU*CNkWJM OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BOYER
Vs.
SWEENEY
Fi Is No. 0806734P
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
PINNACLE HEALTH MED SYS, PO BOX 2253, HARRISBURG PA 17105
TO: ATTN: RADIOLOGY DEPT
(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 0rtS n9AT D 12 IS
AA-
at _
MEDICAL LEGAL RZFRVjjUU'x1ONS-,-TNC, 4940 DYSSTeN ST., -- ---
(Address)
You may deliver or mail legible copies of the documents or produce things requested h?
this subpoena, together with the certificate of compliance, to the party making thi
request at the address listed above. You have the right to seek in advance the rea.onable
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 thin subpoena may seek a court order
c rope l ling you to camp 1 y with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCWING PERSON:
NAPE: JOSEPH R D'ANNUNZIO, ESQ
ADDRESS:
4309 LINGLESTOWN RD
HARRISBURG PA 17112
TELEPHONE : 2i5 B35 ',, , a
SUPREME OOURT ID #
ATTORNEY FOR:
M367282-09
DEFENDANT
DATE: d-W q
Seal of the court
BY THE COURT:
s _
Prothonotary/Clark, Civil Division
?i??'LC.C?Qw
Deputy
(Eff. 7/97)
ADDENDUM TO
SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH MED SYS
ANY AND ALL FILMS, INCLUDING THOSE OF ALL PROVIDERS IN THIS
HEALTH SYSTEM.
PERTAINING TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ORIGINAL X-RAYS REQUESTED
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
PINNACLE HEALTH MED SYS
CUMBERLAND
M367282-09
* * * SIGN AND RETURN THIS PAGE * * *
ryy&xw wTFALTx OF PENNSYLVANIA
COUNry OF COPONERLAND
BOYER
Vs.
SWEENEY
File No. 0806734P
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
LASSES CHIRO CLINIC, 313 S HANOVER ST, CARLISLE PA 17013
TO:
(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 oS nIATTAG D ADn NDIA4
JCJJL:d at _
MEDICAL LEGAL . •, PHIL*., FA -"-
(Address)
You may deliver or mail legible copies of the documents or produce things requested b?
this subpoena, together with the certificate of ccmpliance, to the party making thi-c
request at the address listed above. You have the right to seek in advance the rea,onablc-
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 thi, subpoena may seek a court order
amipe l l i ng you to carp l y with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: JOSEPH R D'ANNUNZIO, ESQ
ADDRESS:
4309 LINGLESTOWN RD
HARRTsRTjRCi, PA 17112
TELEPHONE : 335- 32i2--
SUPREME OOURT ID #
ATTORNEY FOR:
M367282-10
DEFENDANT
DATE : Lrztli? I //, .2 " q
Seal of the Court
BY THE COURT:
S f1. 4,4
Prothonotary Clerk, Civil Division
Deputy
(Eff . 7/97)
Y
ADDENDUM TO
SUBPOENA
BOYER
Vs.
No. 0806734P
SWEENEY
CUSTODIAN OF RECORDS FOR: CASSES CHIRO CLINIC
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: ANGELA BOYER
ADDRESS: 39 VALLEY RD NEWVILLE PA
DATE OF BIRTH: 09/19/74
SSAN: XXXXX3194
ANY AND ALL RECORDS, TESTS AND FILMS.
ORIGINAL X-RAYS REQUESTED
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
LASSES CHIRO CLINIC
CUMBERLAND
M367282-10
* * * SIGN AND RETURN THIS PAGE * * *
FILED-&RCE
OF THE P =" ,.?!-"-^%l NARY
1009 OCT -7 Pty G: 09
Guff v';JiY
ANGELA BOYER and
JOSEPH BOYER, Her Husband
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-6734
V.
CIVIL ACTION - LAW n
LUKE SWEENEY,=
Defendant ?
RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in tlx
Following form:
PETITION FOR APPOINTMENT OF ARBITRATORS `
E?
TO THE HONORABLE, THE JUDGES OF SAID COURT:
I, Joseph R. D'Annunzio, Esquire, counsel for the Defendant in the above action (or
actions), respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiff in the action is $the arbitration limit.
The counterclaim of the Defendant in the action is $0.
N _
CD )
C= -??
C=
.r:. 1
M
c
gj'06'0d_ 47
,t * 1) 75P166 S
/-.# g_y3 3 s3
The following attorneys are interest in the case as counsel or are otherwise disqualified to
sit as arbitrators:
Stephen G Held Esa Stephen L Banko Jr Esq Joseph R. D'Annunzio, Esq.
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
i Tat `?
"e?r
BY:
Date:, 7
Joseph R. D'Annuniio,
Attorney for Defendant
ORDER OF COURT
AND NOW,
petition,
Esq., and
captioned action (or actions) as prayed for.
20 , in consideration of the foregoing
Esq.,
Esq., are appointed arbitrators in the above-
By the Court,
EDGAR B. BAYLEY
ANGELA BOYER and IN THE COURT OF COMMON PLEAS OF
JOSEPH BOYER, Her Husband CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
NO. 08-6734
V.
CIVIL ACTION - LAW t-)
o
_
LUKE SWEENEY, C -i
Defendant ti
Mr -
?V _n
RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the'- r R3
Following form:
PETITION FOR APPOINTMENT OF ARBITRATORS=
TO THE HONORABLE, THE JUDGES OF SAID COURT:
I, Joseph R. D'Annunzio, Esquire, counsel for the Defendant in the above action (or
actions), respectfully represents that:
1. The above-captioned action is at issue.
2. The claim of the Plaintiff in the action is $the arbitration limit.
The counterclaim of the Defendant in the action is $0.
S$W 6 ?d_4
1175 #66 S
?_. 33 s3
The following attorneys are interest in the case as counsel or are otherwise disqualified to
sit as arbitrators:
Stephen G Held Esq Stephen L Banko Jr Esq., Joseph R D'Annunzio Esa
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respectfully submitted,
Date: 71 Zal BY: D?
Joseph R. D'Annunzio, Esquire
Attorney for Defendant
ORDER OF COURT
AND NOW, (4 , 20 in consideration of the foregoing
petition, Esq.,
Esq., and jm?w?' Esq., are appointed arbitrators in the above-
captioned action (or actions) as prayed for.
-51: ihl -z, -7
.r
K)
By the ? /? .
i
a•
???. ?? et
d
ANGELA BOYER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs. NO. 08-6734 CIVIL
LUKE SWEENEY,
Defendant
ORDER
AND NOW, this iy' day of September, 2010, the appointment of a Board of
Arbitrators in the above-captioned case is VACATED. Ron Turo, Esquire, Chairman, shall be
paid the sum of $50.00.
BY THE COURT,
./Ron Turo, Esquire
Court Administrator
:rlm
a/ "1a16(
e°I /
cry
.
f J _1
OF THFILED-OFFICE
AR',`
2010 DEC -6 PM 3: 19
CUMBERLAND COUNT'
PENNSYLVANIA
Stephen G. Held
Attorney ID# 72663
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road, Suite 2
Harrisburg, PA 17110
Telephone: (717) 238-2000 Attorney for Plaintiff(s)
Fax : (717) 233-3029
E-mail: Held@hhrlaw.com
ANGELA BOYER and JOSEPH BOYER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
: NO. 2008-06734
: CIVIL ACTION - LAW
LUKE SWEENEY,
Defendant
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the above captioned matter settled, discontinued and ended.
Respectfully submitted,
Dated: 12/2/10
HANDLER, HENNING & ROSENBERG, LLP
Steph n G. Held, Esquire
I.D. No.: 72663
Attorney for Plaintiffs