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HomeMy WebLinkAbout08-7108IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SUSAN KING, 1939 State Road, Duncannon, PA 17020, Plaintiff, V. BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. Case No: 8- ivil Ienk Civil Action - Law PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in Civil Action - Law in the above case. _X _Writ of Summons shall be issued and forwarded to Sheriff. Date: 2121 SWith Que York, PA 17403 (717) 846-1400 SUMMONS IN CIVIL ACTION STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA TO: Bonnie Dailey, PO Box 39, Jefferson, NY 12093. YOU ARENOTIFIED THAT THE ABOVE-NAMED P INTI F(S) /HAVE COMMENCED AN ACTION AGAINST YOU. Pr onotaw-1 , i ivision Date I By Deputy co 0 J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SUSAN KING, 1939 State Road, Duncannon, PA 17020, Plaintiff, V. BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. Case No: 08-7108 Civil Action - Law AFFIDAVIT OF SERVICE I, Steven D. Stambaugh, Esquire, do hereby certify, subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities, that I am a competent adult and that I have served a true and correct copy of the following document(s): Praecipe for Summons filed of record in this matter or in manner and form as attached upon the ultimate recipient, Bonnie Dailey, by certified mail as verified by the return receipt card attached below. 4--- Date: December 19 , 2008 Respectfully submitted, Steven D. Stambaugh, Esquire Attorney for Plaintiff I.D. No. 64338 2121 South Queen Street York, PA 17403 (717) 846-1400 I STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA C'1 7 ?fn 1 ? BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E-Mail: bkronthal@margolisedelstein.com Attorneys for Defendant, Bonnie Dailey File#20200.4-00017 SUSAN KING VS. BONNIE DAILEY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7108 CIVIL ACTION-LAW JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Defendant, Bonnie Dailey, in the above- aptioned matter. LIS EINSTEIN Date: ID# 55672 `-J 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 1h L CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have this j,") day o , 2009, served a true and correct copy of the following upon the person(s) and in the manner indicated below: Service by First Class Mail, Postage Prepaid. Addressed as Follows: Steve Stambaugh, Esquire 2121 S. Queen Street York, PA 17403 MARGOLIS EDELSTEIN By: Carol Moose M:lmdir\l Main Street America\20200.4-00017 King v. Dai1ey\P1eadings\E0A.a1209.wpd .. ?; .... .? fy : + •.?. ?_ _w ?,? ?,. ?....i S BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E-Mail: bkronthal@margolisedelstein.com Attorneys for Defendant, Bonnie Dailey File# 20200.4-00017 SUSAN KING COURT OF COMMON PLEAS CUMBERLAND COUNTY, VS. PENNSYLVANIA BONNIE DAILEY NO. 08-7108 CIVIL ACTION-LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Rule upon Plaintiff to file a Complaint within twenty (20) days from service hereof or suffer judgment non pros. Date: Camp Hill,, PA 17011 717-975-8114 TO THE PLAINTIFFS: You are hereby ordered and directed to file your Complaint against Defendants in the above-captioned matter within twenty (20) days of service of this Rule against you or suffer judgment non pros. Date: a`t 9 C mberl ounty rothonotary 3510 Trindle Road ?-„ r.a ?? - - ? , ..:: . ?? ? t _;_. _ C... __ ; ?8 = i _ ?Y• .. l? ?~: i, S^. '? " 'v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SUSAN KING, Case No: 08-7108 1939 State Road, Duncannon, PA 17020, Plaintiff, V. Civil Action - Law BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. NOTICE TO DEFEND AND CLAIM RIGHTS 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 notice and pleading are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the pleading or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. Lawyer Referral Service of Cumberland County One Courthouse Square Carlisle, PA 17013 STAMBAUGH LAW. P.C 2121 S. QUEEN ST. YORK, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SUSAN KING, 1939 State Road, Duncannon, PA 17020, Plaintiff, V. BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. Case No: 08-7108 Civil Action - Law AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en persona o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier otra queja o compensacion reclamados por el Demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVARESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE Un ABOGADO, VAYA A O LLAME POR TELEFONO La OFICINA DISPUESTA ABAJO. ESTA OFICINA PUEDE PROVEER De USTED La INFORMACI6N SOME EMPLEAR A un ABOGADO. Si usted no puede permitirse emplear a un abogado, esta oficina puede poder proveer de usted la informacion sobre las agencias que pueden ofrecer servicios juridicos a ]as personas elegibles en un honorario reducido o ningun honorario. STAMBAUGH LAW, P.C. Legal Referral Service of Cumberland County 2121 S. QUEEN ST. One Courthouse Square YORK, PA Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SUSAN KING, Case No: 08-7108 1939 State Road, Duncannon, PA 17020, Plaintiff, V. Civil Action - Law BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. COMPLAINT AND NOW, this ? day of February, 2009, comes the Plaintiff, Susan King, through and by her attorney, Steven D. Stambaugh, Esquire, and files this Complaint, whereof the following is a statement: 1. The Plaintiff, Susan King (hereinafter referred to as "Plaintiff'), is an adult citizen of the Commonwealth of Pennsylvania currently residing at 1939 State Road, Duncannon, Perry County, Pennsylvania 17020. 2. The Defendant, Bonnie Dailey (hereinafter "Defendant"), is an adult citizen of the STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA State of New York with a mailing address of PO Box 39, Jefferson, Schoharie County, New York 12093. 3. The facts and occurrences hereinafter related took place on or about December 26, 2006 at approximately 10:37 a.m. in or around Route 11/15 and Valley Street, East Pennsboro Township, Cumberland County, Pennsylvania. 4. At all times relevant hereto, Plaintiff Susan King was the owner and operator of a 2005 Chevrolet Malibu bearing Pennsylvania registration number GJF3961. 5. At all times relevant hereto, Defendant Bonnie Dailey was the owner and operator of a 1984 Honda Prelude bearing New York registration number CEL7443. 6. At all times relevant hereto, Plaintiff was covered by full tort under Pennsylvania Law or has limited tort with exclusions that apply, or in the alternative, has serious bodily injury as defined by Pennsylvania Law or was not provided proper notice of the limited tort option pursuant to 75 Pa. C. S.A. § 1701 et. seq., specifically § 1705 and § 1791, and other applicable laws and regulations. 7. The said damages, as described hereafter, are in excess of $50,000.00 and outside STAMBAUGH LAW, P.C. the scope and authority of mandatory arbitration and a jury trial is hereby demanded. 2121 S. QUEEN ST. YORK. PA COUNTI Susan King v. Bonnie Dailey 8. Paragraphs one (1) through seven (7) are incorporated by reference as if set forth fully hereunder. 9. Plaintiff, at or about the aforementioned date and time, stopped her vehicle for a red traffic signal behind two already stopped vehicles and which were traveling southbound on Route 11/15 at the intersection of Route 11/15 and Valley Street. 10. While Plaintiff was stopped in stopped traffic, Defendant violently slammed her vehicle into the rear of a second vehicle owned by David Morris, III, and thereby catapulting Mr. Morris' car into the rear of Plaintiff's vehicle. 11. Said accident was directly and proximately caused by Defendant's negligence, carelessness and recklessness which consisted of the following: a) Operating said motor vehicle without due regard to the rights, safety, and position of Plaintiffs vehicle; STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. i YORK, PA b) Failing to have said vehicle under proper control so as to prevent the same from colliding with Plaintiffs vehicle; C) Failing to keep a proper lookout for other vehicles lawfully on the road; d) Failing to operate said vehicle with due regard for the highway and traffic conditions which were then and there existing and of which he/she was or should have been aware; e) Failing to take evasive action in order to avoid impacting the Plaintiffs vehicle; and f) Violating 75 Pa.C.S.A. §3714 by driving said vehicle in careless disregard for the safety of persons or property. 12. Said accident resulted solely from Defendant's aforesaid joint and several negligence, carelessness and recklessness and was in no way the result of any act or failure to act on the part of the Plaintiff. 13. STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA As a direct and proximate result of Defendant's aforesaid negligence, carelessness and recklessness, Plaintiff has sustained personal injuries resulting in serious impairment of bodily function which include, but are not limited to, the following: a) Physical pain and suffering resulting from right shoulder, cervical, lumbar spine injuries; b) Mental anguish; C) Discomfort; d) Inconvenience; e) Distress; f) Loss of life's pleasures; g) Embarrassment and humiliation; h) An impairment of health and sense of well being; and i) Disfigurement. 14. As a direct and proximate result of Defendant's aforesaid negligence, carelessness and recklessness, Plaintiff has suffered, is suffering, and in the future will continue to suffer financial injuries which include, but are not limited to, the following: a) Past, present, and future medical expenses which have or may in the future exceed applicable legal limits; b) Incidental costs resulting from dealing with said injuries; and c) Loss of earnings and earning capacity. STAMBAUGH LAW, P.C.I 1 2121 S. QUEEN ST. YORK, PA Wherefore, Plaintiff Susan King respectfully requests that this Honorable Court enter judgment against Defendant, Bonnie Dailey, in an amount in excess of $50,000.00, plus delay damages, costs, interest and such other and further relief as allowed by law. Date: February 5 2009 2121 South Queen Street York, PA 17403 (717) 846-1400 VERIFICATION I verify that the statements made in this LnAWTY??STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language is that of counsel and not my own. To the extent that the contents are based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents are that of counsel, I have relied upon my counsel in making this verification. I understand that false statements herein are made subject to penalties of 18 PA C.S. §4904, relating to unworn falsification to authorities. ra)'?q Date - C?? k?'? Susan King IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SUSAN KING, 1939 State Road, Duncannon, PA 17020, Plaintiff, V. BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. Case No: 08-7108 Civil Action - Law CERTIFICATE OF SERVICE I, Rachelle L. Seeds, of the law firm of Stambaugh Law, P.C., attorneys for Plaintiff, do hereby certify that I am this day serving a copy of the foregoing Complaint upon counsel in the following manner. BY FIRST CLASS MAIL: Barry A. Kronthal, Esquire Shaun J. Mumford, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA $ta m gh Law, P.C. _ Date: February CQ42009 Ra elle L. See , ara egal to: Steven D. Stambaugh, Esquire I.D. # 64338 Attorney for Plaintiff 2121 South Queen Street York, PA 17403 (717) 846-1400 c?? ^' ?, rr7> -•p-y ?T..? E?? - ? _ _ ,? ?. ?` ?'2 ['3'! Lr 4" ? ?(;? . .. _ x. - , { r.- ` ! ...r. - i. ! S? ,C .. ? ? --C CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN KING TERM, CUMBERLAND -VS- CASE NO: 08-7108 BONNIE DAILEY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, 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: 08/10/2009 MCS on behalf of // / /S/ Aarrq -X -AronthaC, C-O-Jq. BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0945278 44531-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: SUSAN KING -VS- BONNIE DAILEY COURT OF COMMON PLEAS TERM, CASE NO: 08-7108 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 EAST PENNSBORO AMBULANCE CO. HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HEALTHSOUTH HEALTHSOUTH REHAB CUMBERLAND FAMILY PRACTICE ORTHOPAEDIC & SPINE SPECIALIST RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL AND X-RAY MEDICAL AND X-RAY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: STEVEN D. STAMBAUGH, ESQ., PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, 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: 07/18/2009 MCS on behalf of BARRY A. KRONTHAL, ESQ Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ STEVEN D. STAMBAUGH, ESQ. L/O OF STEVEN STAMBAUGH 2121 S. QUEEN STREET YORK, PA 17403 - 20200.4-00017 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.86S 133-H DE02-0537952 44531-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN KING File No. 08-7108 VS. BONNIE DAILEY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for EAST PENNSBORO AMBULANCE CO (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: BARRY A. KRONTHAL. ESQ. ADDRESS: _3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 'AUG 10 2009 Date: 7&1161 Seal of the Court BY THE COURT: A/ &4e ? Prothonotary/Clerk, Civil Divisio Deru 44531-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EAST PENNSBORO AMBULANCE CO. 750 S. HUMER STREET P.O. BOX 47 ENOLA. PA 17025 RE: 44531 SUSAN KING Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ANY AND ALL RECORDSS FROM 12/26/06 REGARDING A CRASH IN EAST PENNSBORO TOWNSHIP, ROUTHE 11/15 AND VALLEY STREET. Dates Requested: for 12-26-2006 only. Subject : SUSAN KING 405J NORTH HIGH STREET, DUNCANNON, PA 17020 Social Security #: XXX-XX-6583 Date of Birth: 09-07-1959 R1.86S 133-H SU10-0795028 44531-LO1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN KING TERM, CUMBERLAND -VS- CASE NO: 08-7108 BONNIE DAILEY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, 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: 08/10/2009 MCS on behalf of /S/ Barry .J`ronthaC, Cfolic'. BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0945282 44531-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN KING File No. 08-7108 vs. BONNIE DAILEY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group- Inc. 1601 Market Street. Suite 800, Philadelphia- PA 1910' 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: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDL.E ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 10 2009 Date: 1// & I Seal of the Court BY THE COURT: /I/ &&?j r LI)4 y Prothonotary/Clerk, Civil Division Dep 4453.1-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL MEDICAL RECORDS 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 44531 SUSAN KING Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, 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: from: 01-01-2000 to 07-06-2009. Subject : SUSAN KING 4051 NORTH HIGH STREET, DUNCANNON, PA 17020 Social Security #: 204-46-6583 Date of Birth: 09-07-1959 21.86s 133-H SU10-0795030 44531-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUSAN KING -VS- BONNIE DAILEY COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-7108 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, 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: 08/10/2009 MCS o,//n? behalf of // /S/ !/marry J. Jlronthal BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0945285 44531-LO3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN KING File No. 08-7108 vs. BONNIE DAILEY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED 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: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TR_INDL.E ROAD CAMP HILL, PA 17011 TELEPHONE: _(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant `AUG 10 2009 Date: M Seal of the Court BY THE COURT: 1V && - Prothonotary/Clerk, 6ivil/D, Rvion Deputy 44531-03 , EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL RADIOLOGY DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 44531 SUSAN KING Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-2000 to 07-06-2009. Subject : SUSAN KING 4051 NORTH HIGH STREET, DUNCANNON, PA 17020 Social Security #: 204-46-6583 Date of Birth: 09-07-1959 z1.86S 133-H SU10-0795032 44531-LO3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUSAN KING -VS- BONNIE DAILEY COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-7108 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, 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: 08/10/2009 MCS on behalf of /// // /S/ 1 arry -4. -Aronthal" -0Jq. BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0945288 44531-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN KING VS. BONNIE DAILEY File No. 08-7108 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO Custodian of Records for HEALTHSOUTH (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: BARRY A. KRONTHAL. ES ADDRESS: 3510 TRINDLE ROAD TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 10 2009 Date: Im 9 Seal of the Court BY THE COURT: 1ST ? ,?1?'n Prothonotary/Clerk, Civil Division J 6A' Depu 44531-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH 175 LANCASTER BLVD. MECHANICISBURG, PA 17055 RE: 44531 SUSAN KING Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and 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, consultation, care or treatment pertaining to: Dates Requested: from: 01-01-2000 to 07-06-2009. Subject : SUSAN KING 4051 NORTH HIGH STREET, DUNCANNON, PA 17020 Social Security #: XXX-XX-6583 Date of Birth: 09-07-1959 22.19 120-H SU10-0795468 44531-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUSAN KING -VS- BONNIE DAILEY COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-7108 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, 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: 08/10/2009 /S/ 12arry A. J ronthaC, BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0945291 44531-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN KING vs. BONNIE DAILEY File No. 08-7108 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOUTH REHAB (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 ATTACHFD RIDER * * * * at The MC4 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: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE, ROAD _CAMP HILL- PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG /?10 2009 Date: t/ L(/ I Seal of the Court BY THE COURT: ?j Ah&'4 Y4 - Prothonotary/Clerk, Civ I Division 411 1164, 1 CLe?? -J Deputy 44531-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB 840 N. FRONT STREET WORMLEYSBURG, PA 17043 RE: 44531 SUSAN KING Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and 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, consultation, care or treatment pertaining to: Dates Requested: from: 01-01-2000 to 07-06-2009. Subject : SUSAN KING 405J NORTH HIGH STREET, DUNCANNON, PA 17020 Social Security #: XXX-XX-6583 Date of Birth: 09-07-1959 82.19 120-H SU10-0795470 44531-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUSAN KING -VS- BONNIE DAILEY COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-7108 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, 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: 08/10/2009 MCS on behalf]] of // /S/ Barry -Aronthali, Co3q. BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0945294 44531-LO6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN KING vs. BONNIE DAILEY File No. 08-7108 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CUMBERLAND FAMILY PRACTICE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS 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: BARRY A. KRONTHAL. ES ADDRESS: 3510 TRINDLE ROAD TELEPHONE: (215).246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 10 2009 Date: Z/( _bU Seal of the Court BY THE COURT: ?J Prothonotary/Clerk, Civil Division MgUW Deputy/ 44531-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND FAMILY PRACTICE 4470 VALLEY STREET ENOLA, PA 17025 RE: 44531 SUSAN KING Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and 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, consultation, care or treatment pertaining to: Dates Requested: from: 01-01-2000 to 07-06-2009. Subject : SUSAN KING 4051 NORTH HIGH STREET, DUNCANNON, PA 17020 Social security #: XXX-XX-6583 Date of Birth: 09-07-1959 R1.86S 133-H SU10-0795038 44531-LO6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUSAN KING BONNIE DAILEY -vs- COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-7108 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, 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: 08/10/2009 MCS on behalf of / /S/ 12arry ? J ront4aC, C'o-ick. BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT R1.86S 133-H DE11-0945297 44531-L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN KING VS. BONNIE DAILEY File No. 08-7108 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO Custodian of Records for ORTHOPAEDIC & SPINE SPECIALIST (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: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: _(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 10 2009 Date: Seal of the Court BY THE COURT: J &&b Y/ Prothonotary/Clerk, Civil Division Depu 44531-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC & SPINE SPECIALIST 1855 POWDER MILL ROAD YORK, PA 17402 RE: 44531 SUSAN KING Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and 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, consultation, care or treatment pertaining to: Dates Requested: from: 01-01-2000 to 07-06-2009. Subject : SUSAN KING 4051 NORTH HIGH STREET, DUNCANNON, PA 17020 Social security #: XXX-XX-6583 Date of Birth: 09-07-1959 t1.86S 133-H SU10-0795040 44531-LO7 C"?- Yi??`i ?? ? ? `r7?? ?,,nn a , ? jj_ {. t _ ? _.. .. r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SUSAN KING, Case No: 08-7108 1939 State Road, Duncannon, PA 17020, Plaintiff, V. Civil Action - Law BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. PRAECIPE TO SATISFY, DISCONTINUE & END TO THE PROTHONOTARY: Please mark the above captioned case settled and satisfied and discontinued. Stambaugh Date: October, 2009 I. 643 21n1 SoutlYQueen Street York, PA 17403 (717) 846-1400 STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Case No: 08-7108 Civil Action - Law CERTIFICATE OF SERVICE I, Rachelle L. Seeds, of the law firm of Stambaugh Law, P.C., attorneys for SUSAN KING, 1939 State Road, Duncannon, PA 17020, Plaintiff, V. BONNIE DAILEY, PO BOX 39, JEFFERSON, NY 12093, Defendant. Plaintiff, do hereby certify that I am this day serving a copy of the foregoing Plaintiff's Praecipe to Satisfy upon counsel in the following manner. BY FIRST CLASS MAIL: Barry A. Kronthal, Esquire Shaun J. Mumford, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 STAMBAUGH LAW, P.C. 2121 S. QUEEN ST. YORK, PA augh Law, P.C. Date: October ?e),2009 Rachelle L. Seeds, Paralegal to: Steven D. Stambaugh, Esquire I.D. # 64338 Attorney for Plaintiff 2121 South Queen Street York, PA 17403 (717) 846-1400 Fl?EC`?'+?r? ICS 20H OC T 30 Pii 3: 32