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HomeMy WebLinkAbout04-2029IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, NO. 04-2029 Plaintiff, VS. PATRICIA BENDER, Defendant. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Casey G. Shore, Esquire NEALON & GOVER 2411 North Front Street Harrisburg, PA 17110 Attorneys for Defendant Amie G. Tannenbaum 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 no objection is made, the Subpoena may be served. Dated: M6 --7t-/'Z C'a& Thomas R. Campbell CAMPBELL & WHITE, P.C. 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorneys for Plaintiff -1- 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: Thomas R. Campbell, Esquire Attorney I.D. #: 75978 CAMPBELL & WHITE, PC. 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorneys for Plaintiff Dated: BY THE COURT: By: s if 2o,t- a Mothonotary , -2- f..,.. } ?? __ l.. .. __f _. r?? ,I . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, NO. 04-2029 Plaintiff, VS. PATRICIA BENDER, Defendant. CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Thomas R. Campbell, Esq., Attorney for Plaintiff, certifies that: (1) A Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least Twenty (20) days prior to the date on which the Subpoena is sought to be served; (2) a copy of the Notice of Intent, including the proposed Subpoena, 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. Dated: lA Q& Thomas R. Ca pbell CAMPBELL & WHITE, P.C. 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorney for Plaintiff -1- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM : NO.: Oq -ACol? Plaintiff, VS. PATRICIA BENDER, Defendant. PRAECIPE FOR ISSUANCE OF WRIT OF SUMMONS TO: Curtis S, Long, Prothonotary You are hereby notified that Amie G. Tannenbaum, Plaintiff herein, has CAMPBELL & WHITE ATTORNEYS AT LAW z en?nwxe srxcet uF.t'iYV'bti0.<I, VENNSYI I'?N111'?U ( in ll..41Iv commenced an action against Patricia Bender, Defendant. Please issue a Writ of Summons for a Civil Action in the above-captioned matter, Dated: Thomas R. Ca bell, Esq. Attorney I.D. #: 75978 CAMPBELL & WHITE, P.C. 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorney for Plaintiff r ' V 1 c? Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS AMIE G. TANNENBAUM Court of Common Pleas Plaintiff Vs. No. 04-2029 CIVIL TERM In CivilAction-Law PATRICIA BENDER 101 CLARKTON COURT LEMOYNE, PA 17043 Defendant To PATRICIA BENDER, You are hereby notified that AMIE G. TANNENBAUM, the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) CURTIS R. LONG Prothonotary nGy?/? Date MAY 5, 2004 `Rv /Zoq p 1 ; 1 / 1V1Z 3CLJ Deputy C Attorney: Name: THOMAS R. CAMPBELL, ESQUIRE Address: CAMPBELL & WHITE, P.C. 112 BALTIMORE STREET GETTYSBURG, PA 17325 Attorney for: Plaintiff Telephone: 717-334-9278 Supreme Court ID No. 75978 SHERIFF'S RETURN - REGULAR CASE NO: 2004-02029 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TANNENBAUM AMIE G VS BENDER PATRICIA VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon BENDER PATRICIA the DEFENDANT , at 1907:00 HOURS, on the 20th day of May , 2004 at 101 CLARKTON COURT LEMOYNE, PA 17043 by handing to PATRICIA BENDER 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 18.00 Service 11.04 Affidavit .00 Surcharge 10.00 .00 39.04 Sworn and Subscribed to before me this ,Z9'= day of wY A. D. r thonotary So Answers: R. Thomas Kline 05/21/2004 CAMPBELL & WHITE By : , ?/, Deputy Sher'-?ft AMIE G. TANNENBAUM, Plaintiff VS. PATRICIA BENDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2029 CV CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Patricia Bender, with regard to the above-captioned matter. Respectfully submitted, NEALON, GOVER & PERRY By: lo".c- Ca G. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: 05 CERTIFICATE OF SERVICE AND NOW, this ?Tt+ day of March, 2005, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Thomas R. Campbell, Esquire Campbell & White, P.C. 112 Baltimore Street Gettysburg, PA 17325 -7-Case. Shore, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, NO.: 04-5-2029 Plaintiff, VS. : JURY TRIAL DEMANDED PATRICIA BENDER, Defendant. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Ms. Patricia Bender C/o Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 Attorneys for Defendant You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within Twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without your and judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Adams County Courthouse 111-117 Baltimore Street Gettysburg, PA 17325 Telephone: (717) 334-6781 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, NO.: 04-2029 Plaintiff, VS. JURY TRIAL DEMANDED PATRICIA BENDER, . Defendant. . COMPLAINT Arnie G. Tannenbaum, Plaintiff herein, by her attorneys, Campbell & White, P.C., files this Complaint and states the following: 1. Plaintiff Arnie G. Tannenbaum is a competent adult individual who currently resides at 323 Pine Street, Gettysburg, Adams County, Pennsylvania 17325. 2. Defendant Patricia Bender is a competent adult individual who resides at 101 Clarkton Court, LeMoyne, Cumberland County, Pennsylvania 17043. 4. The facts and circumstances hereinafter related took place on or about August 15, 2002, at approximately 3:45 o'clock P.M. on South Third Street, in LeMoyne, Cumberland County, Pennsylvania. 5. At that time, Plaintiff Arnie G. Tannenbaum was operating her 1990 Toyota Canny in a mostly northerly direction on South Third Street. b. At that time and place, Defendant Patricia Bender was operating her 2000 Honda Accord west on Bosler Avenue. 7. At that time and place, Defendant Patricia Bender failed to stop at the stop sign at the intersection of Bosler Avenue and South Third Street. 8. At that time and place, Defendant Bender ran through the stop sign and attempted to cross South Third Street directly in front of Plaintiff's vehicle. At that time and place, the front driver's side portion of Defendant's vehicle violently collided with the front passenger side portion of Plaintiff's vehicle as she entered Plaintiff's lane of travel. The impact pushed Plaintiff's vehicle across the roadway. 10. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Amie G. Tannenbaum, are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Bender operated her motor vehicle as follows: A. Failure to bring her vehicle to a complete stop at a lawfully- posted stop sign; B. failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; C. failure to apply her brakes in sufficient time to avoid striking the front of Plaintiff's vehicle; D. failure to yield the right-of-way to Plaintiff's vehicle; E. failure to drive her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; F. failure to keep proper and adequate control over her vehicle; G. operating her vehicle in violation of §3323 of the Motor Vehicle Code of the Commonwealth of Pennsylvania; -2- H. operating her vehicle in violation of §3361 of the Motor Vehicle Code of the Commonwealth of Pennsylvania; I. operating her vehicle in violation of §3736 of the Motor Vehicle Code of the Commonwealth of Pennsylvania; J. otherwise driving her vehicle upon the roadways in a manner endangering persons and property, and in a reckless manner with careless disregard to the rights and safety of others. 11. All of the foregoing was a breach of Defendant Patricia Bender's duty of reasonable care in the operation of her vehicle. COI NT i Arnie G. Tannenbaum,Plaintiff VS. Patricia Bender, Defendant Negligence 12. Paragraphs 1 through 11 of the Complaint are incorporated herein by reference as if set forth in full. 13. Plaintiff Arnie G. Tannenbaum sustained painful and severe injuries, which include, but are not limited to: (a) Torn right rotator cuff; (b) cervical disc injury; (c) cervical sprain/strain; and (d) extreme bruising throughout her chest and rib cage. 14. By reason of the aforesaid injuries sustained by Plaintiff Arnie G. -3- Tannenbaum, she was forced to incur liability for medical treatment, medications, hospitalizations, surgeries, and similar miscellaneous expenses in an effort to restore herself to health, and a claim is made therefor. 15. Because of the nature of her injuries, Plaintiff Arnie G. Tannenbaum has been advised, and therefore, avers that she may be forced to incur similar expenses in the future, and a claim is made therefor. 16. As a result of the aforementioned injuries, Plaintiff Arnie G. Tannenbaum has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and a claim is made therefor. 17. As a result of the aforementioned injuries, Plaintiff Arnie G. Tannenbaum has sustained work loss, loss of opportunity, and a permanent impairment of her earning power and capacity, and a claim is made therefor. 18. Plaintiff Amie G. Tannenbaum continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries are or may be of a permanent nature, causing residual problems for the remainder of her lifetime, and a claim is made therefor. 19. As a result of the aforesaid accident, Plaintiff Arnie G. Tannenbaum has sustained scars, which result in permanent disfigurement, and a claim is made therefor. WHEREFORE, Plaintiff Arnie G. Tannenbaum demands judgment against -4- Defendant Patricia Bender in an amount in excess of $100,000.00, exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully submitted: CAMPBELL & WHITE, P.C. jzG'?e?e Thomas R. Campbell Attorney I.D.#: 75978 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorneys for Plaintiff -5- VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Amie G. Tannenbaum Dated: C? 71-k d 6 aso 5 U i -6- ?? ?, ?_:_; -?. ?„ - -. , - ( ? ?, v ? -r r??. G.J r., r r; ? - _ _ W -G 1 Q? AMIE G. TANNENBAUM, Plaintiff VS. PATRICIA BENDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2029 CV CIVIL ACTION - LAW NOTICE TO PLEAD TO: Arnie G. Tannenbaum c/o Thomas R. Campbell, Esquire Campbell & White, P.C. 112 Baltimore Street Gettysburg, PA 17325 YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. By Respectfully submitted, NEALON GOVER & PERRY Case,,ry. Shore, Esquire Attorney I.D. No. 85321 2411 North Front St. Harrisburg, PA 17110 Date: OJ Infi (717) 232-9900 AMIE G. TANNENBAUM, Plaintiff VS. PATRICIA BENDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2029 CV : CIVIL ACTION -LAW ANSWER WITH NEW MATTER 1. Admitted based upon information and belief. 2. Admitted based upon information and belief. 3. No response required. The Plaintiff's Complaint lacks paragraph 3. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. 8. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. 9. Admitted in part, denied in part. It is admitted at that time and place the front driver's side portion of the Defendant's vehicle collided with the front passenger side of the Plaintiffs vehicle. All other averments contained within this paragraph are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. 10. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. 11. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. 12. No response required. 13-19. Denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, the Defendant respectfully requests that the Complaint be dismissed with costs to be paid by the Plaintiff. NEW MATTER 20. Paragraphs 1 - 19 of the Defendant's Answer are incorporated herein by reference thereto. 21. Plaintiff's complaints are barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, the Defendant respectfully requests that the Complaint be dismissed with costs to be paid by the Plaintiff. Respectfully submitted, NEALON GOVER & PERRY By: Ca G. Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 7171232-9900 Date: CA- VERIFICATION I, PATRICIA BENDER, verify that the statements made in the foregoing ANSWER WITH NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: 5- l7 - OS1 PATRICIA BENDER CERTIFICATE OF SERVICE AND NOW, this , /0 day ofIUY; 2005, 1 hereby certify that I have served the foregoing ANSWER WITH NEW MATTER on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Douglas R. Bare, Esquire The Law Firm of Douglas Bare 35 South Queen Street York, PA 17403 Lzi L Ca hore, Esquire P 4 ? 5T i GL . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, NO.: 04-2029 Plaintiff, VS. JURY TRIAL DEMANDED PATRICIA BENDER, Defendant. PLAINTIFF'S ANSWER TO NEW MATTER 20. Paragraphs 1. through 19. of Plaintiff's Complaint are incorporated herein by reference thereto. 21. Denied. Paragraph 21. of Defendant's New Matter states a legal conclusion to which no responsive pleading is required. If a response is required, the averments are specifically denied. WHEREFORE, Plaintiff Amie G. Tannenbaum respectfully request that Defendant's New Matter be dismissed and judgment entered in Plaintiffs favor and against Defendant in accordance with Plaintiff's Complaint. Dated: / 'jQ?OS Respectfully submitted: CAMPBELL & WHITE, P.C. f Thomas R. Ca pbell Attorney I.D.#: 75978 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorneys for Plaintiff VERIFICATION I, Thomas R. Campbell, do hereby verify, as attorney of record on behalf of the Plaintiff herein, that the statements made in the foregoing Answer to New Matter are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Thomas R. Campbell Attorney for Plaintiff Dated: (? - (U - d 9- -2- N C. ? T i) ? ) A . =?3 0 CERTIFICATE VPQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS 1N THE MATTER OF: I TANNENBAUY -vs- AR TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. C DATE: 07/13/2005 /s/ NC on behalf o CA Y SHO , E Q. Attorney or DEFENDANT DE11-572044 0 3 1 6 7- Z DE02-304307 O 3 1 6 7_ C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS MEDICAL RECORDS INSURANCE fi A:RAYS fi A:RAYS fi A:RAYS & A:RAYS & XRAYS DE(12-304307 0 3 1 6 7- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM vs. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUL1E 4009.22 TO: Custodian of Records for HANOVER ORTHOPAEDIC ASSOC. (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: CASEY SHORE. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 3 2005 Date: JLt.JE- .2O aZ06X Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Div Deputy 03167-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HANOVER ORTHOPAEDIC ASSOC. 207 BLOOMING GROVE RD. HANOVER, PA 17331 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and./or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject : ANM TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU10-570316 0 3 1 6 7- 1, 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-572095 0 3 1- 6 7- L 0 2 C O M M O N W E A L T H OP P E N N S 5r L VAN 2 A COUNT Y O EP C UMBER LAN D IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODIICE DOCUNLBNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN MCS on behalf of CASEY SHORE, ESQ. .Attorney for DEFENDANT Any questions regarding this matter, contact 'THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 1 6 7- C O 2 >>> LOCATION LIST <<< PAGE: LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS k XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 1 6 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM vs. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HANOVER GENERAL 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 Gm" Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19 ]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: CASEY SHORE. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 3 2005 Date: LA) C ..20 -q6&5 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil ivisiprp' Deputy 03167-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HANOVER GENERAL HOSPITAL 300 HIGHLAND AVE. HANOVER, PA 17331 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security !/: 212-42-9422 Date of Birth: 01-08-1942 SU10-570318 0 3 1 6 7- L 0 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, E 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: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-572096 0 3 1 6 7- L 0 3 C O M M O N W E A L T H OF' P E N N S Y L VAN 2 A COUNT Y OF C UM B E R L AN D IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT 'THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 1 6 7- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 1 6 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM File No. _ 04-2029-CV vs. BENDER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HANOVER GENERAL 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: CASEY SHORE. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 3 2005 Date: ?/((J P C? J 0?9 $ Seal of the Court 03167-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HANOVER GENERAL HOSPITAL 300 HIGHLAND AVE. HANOVER, PA 17331 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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: up to and including the present. Subject : WEE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU:LO-570320 0 3 1 6 7- 1, 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-572097 0 3 1 6 7- 1,0 4 C O M M O N W E A L T H OF P E N N S Y L VAN T A COUNTY OF C UMBER L.AN D IN THE MATTER OF; COURT OF COMMON PLEAS TANNENBAUM -VS- BENDER A SUBPOENA TO [ Note: see enclosed list of locations I TERM, CASE NO; 04-2029-CV TO: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 1 6 7- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 1 6 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM vs. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUL1E 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: CASEY SHORE. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 8 2005 Date: C1.J R -.2 ?d 6Z5 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil D?ivis7io Deputy 03167-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HEALTHSOUTH 7900 SUDLEY ROAD SUITE 803 MANASSAS, VA 20109 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician s, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU7.0-570322 0 3 1 6 7- 1,0 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-572098 0 3 1 6 7- L 0 S C O M M O N W E A L T H OP P E NN S Y L VANS A COUNTY OF' CUMBERI1181ND IN THE MATTER OF: COURT OF COMMON PLEAS TANNENBAUM -VS- BENDER OF INTENT TO SERVE A TERM, CASE NO: 04-2029-CV [ Note: see enclosed list of locations ) TO: THOMAS R_ CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - MCS on behalf of -CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 1 6 7- C O 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D_ GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 3-6 7-Co 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM vs. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RAJESH BAJAJ. MD (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 500. 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: CASEY SHORE. ESO. ADDRESS: 2411 N. FRONT T. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 3 2005 Date: JtLoe 26?o&s Seal of the Court BY T E COURT: - . Prothonotary/Clerk, Civil Drvisio Deputy 03167-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RAJESH BAJAJ, MD 147 N. WASHINGTON ST. GETTYSBURG, PA 17325 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU10-570324 0 3 1 6 7- L 0 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -vs- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-572099 0 3 1 6 7- L 06 C O M M O N W E A L T H OP P E NN S )rTL VAN T A COUNT Y O EP C U M B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS TANNENBAUM _VS_ BENDER E OF INTENT TO SERVE A FOR TERM, CASE NO: 04-2029-CV [ Note: see enclosed list of locations ) TO: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - MCS on behalf of -CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 033-67-C02 LOCATION LIST PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS 6 XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & X]RAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & X]RAYS MEDICAL RECORDS & X:RAYS INSURANCE DE02-304307 03 1 6 7-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM VS. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GETTYSBURG 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: CASEY SHORE, ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY TIjE COURT: Prothonotary/Clerk, Civil JUL 1 3 2005 Deputy Date: ? t ? 32 f) ;2 e06' Seal of the Court 03167-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GETTYSBURG HOSPITAL 147 GETTYS STREET GETTYSBURG, PA 17325 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and-all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU"LO-570326 0 3 1 6 7- 1, 0 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-572100 0 3 1 6 7- 1,0 7 C O M M O N W E A L T H OF, P E NN S Y'L VAN T A COUNTY OF C UMBER L,AN D IN THE MATTER OF: COURT OF COMMON PLEAS TANNENBAUM TERM, -VS- CASE NO: 04-2029-CV BENDER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUNNKNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served- Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 MCS on behalf of CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - Any questions regarding this matter, contact CASEY SHORE, ESQ. -Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 1 6 7-CO 2 >>> LOCATION LIST « PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HBALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 1 6 7-CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM VS. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GETTYSBURG 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: CASEY SHORE. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 3 2005 Date: 1_ 0 h e266S Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divisio Deputy 03167-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GETTYSBURG HOSPITAL 147 GETTYS STREET GETTYSBURG, PA 17325 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 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: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU10-570328 031_67-L 07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DELI-572101 03167-L 08 C O M M O N W E A L T H op P E N N S ?'L VAN I A COUNT Y OP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS TANNENBAUM TERM, -VS- CASE NO: 04-2029-CV BENDER INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUM INGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations J TO: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - MCS on behalf of -CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 1 6 7-CO 2 >>> LOCATION LIST «< PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 1 6 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM vs. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUL1E 4009.22 TO: Custodian of Records for JOANNE CHAN. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun. Inc.- 1601 Market Street. Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ES ADDRESS: 2411 N FRONT ST TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 3 2005 Date: 'J U.A-) e- ,,2 0 n&-g Seal of the Court BY T,)iE COURT: Prothonotary/Clerk, Civil Divisio Deputy 03167-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR JOANNE CHAN, M.D. 5615 YORK ROAD INTERNAL MED. ASSOC. NEW OXFORD, PA 17350 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security J{: 212-42-9422 Date of Birth: 01-08-1942 SU10-570330 0 3 1 6 7- L 0 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE11-572102 0 3 1 6 7- 1, 0 9 C O M M O N W E A L T H OP P E N N S -1'L VAN I -A. COUNTY OF' C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS TANNENBAUM TERM, -VS- CASE NO: 04-2029-CV BENDER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations I TO: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - MCS on behalf of -CASEY SHORE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 3-6 7-CO 2 >>> LOCATION LIST «< PAGE: 1 LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS k XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 1 6 7-CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM File No. _ 04-2029-CV vs. BENDER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CO SPORTS PHYSICAL THERAPY (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 Croun Inc 1601 Market Street. Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESQ. ADDRESS: 2411 N FRONT T. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1 3 2005 Date: JLLJF_ ?r? ???? Seal of the Court BY SHE COURT: Prothonotary/Clerk, Civil 4Divisii G/A 2 Deputy 03167-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GO SPORTS PHYSICAL THERAPY 705 OLD HARRISBURG RD GETTYSBURG, PA 17325 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU:LO-570332 0 3 1 6 7- L 0 9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, ESQ. certifies that (1) A notice of intent to serve the subpoena witt. 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: 07/13/2005 CASEY SHORE, ESQ. Attorney for DEFENDANT DE:_1-572103 0 3 1 6 7- L 1 0 C O M M O N W E A L 17H OF P E N N S Y L VAN: EA COUNTY OF C UMBER LEAN D IN THE MATTER OF: TANNENBAUM _VS_ BENDER A SUBPOENA ( Note: see enclosed list of locations .I COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV TO: THOMAS R_ CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/23/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - Any questions regarding this matter, contact MCS on behalf of -CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-304307 0 3 1 6 7- C 0 2 >>> LOCATION LIST <<< PAGE: LOCATION NAME RECORDS REQUESTED HANOVER ORTHOPAEDIC ASSOC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HEALTHSOUTH RAJESH BAJAJ, MD GETTYSBURG HOSPITAL GETTYSBURG HOSPITAL JOANNE CHAN, M.D. GO SPORTS PHYSICAL THERAPY SHELBY INSURANCE CO. MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XF:AYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS INSURANCE DE02-304307 0 3 1 6 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM File No. _ 04-2029-CV vs. BENDER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE; 4009.22 TO: Custodian of Records for SHELBY INSURANCE 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 MCos roun 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 coraply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CASEY SHORE. ESQ. ADDRESS: 2411 N FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 13 2005 Date: Jli,,-F ) 66S Seal of the Court Deputy 03167-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHELBY INSURANCE CO. 3760 RIVER RUN DRIVE P.O. BOX 43360 BIRMINGHAM, AL 43243 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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 foam, pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security f{: 212-42-9422 Date of Birth: 01-08-1942 Date of Loss: 08/15/2002 SU10-570334 0 3 1 6 7- T. 1 0 C . c?i, -rt on T 1 _jCi) r _.' `ern ?7 cn no CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of CASEY SHORE, E 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: 08/17/2005 61 MC on beha f of C SEY RE, ESQ. Attorn for DEFENDANT DEII-579413 0 3 2 6 7- 1, 1 1 Comm O N W E AL T H OF P E NN S Y L VAN 2 A COUNTY OF CUMBER LAND IN THE MATTER OF: TANNENBAUM -VS- BENDER COURT OF COMMON PLEAS TERM, CASE NO: 04-2029-CV NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 GENTILE HAND CLINIC MEDICAL RECORDS & KRAYS T0: THOMAS R. CAMPBELL, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office- DATE; 07/28/2005 CC: CASEY SHORE, ESQ. - 05-154 PATRICIA HOFFMAN - Any questions regarding this matter, contact MCS on behalf of CASEY SHORE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-307821 033-67-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TANNENBAUM vs. BENDER File No. 04-2029-CV SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GENTILE HAND CLINIC (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, Suit 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: CASEY SHORE ES ADDRESS: 2411 N_ FRONT ST. _HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, ?JG . t6ua Deputy Date: .? /(, -, Qps Seal of the Court 03167-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR GENTILE HAND CLINIC 1010 EICHELBERGER ST. SUITE 5 HANOVER, PA 17331 RE: 3167 AMIE TANNENBAUM Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, 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 or treatment pertaining to: Dates Requested: up to and including the present. Subject : AMIE TANNENBAUM 323 PINSE STREET, GETTYSBURG, PA 17325 Social Security #: 212-42-9422 Date of Birth: 01-08-1942 SU10-515950 0 3 1 6 7- L 1 1. =? b g-- ? ;. ? ?T A R7 AJ F N ?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, Plaintiff, NO.: 04-2029 VS. PATRICIA BENDER, Defendant. JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this IS day of October, 2005, I hereby certify that a copy of a Notice of Deposition was served relative of the Plaintiff in the above-captioned action on the persons listed below in the manner indicated: Depositing in the U.S. Mail, at the Post Office at Gettysburg, Pennsylvania, first class mail, postage prepaid, to: Casey G. Shore, Esquire NEALON, GOVER & PERRY 2411 Front Street Harrisburg, PA 17110 Attorneys for Defendant Deborah L. Zepp Court Reporting 121 State Street York Springs, PA 17372 Stenographer --t- /Z Thomas R. Ca Abell, Esquire CAMPBELL & WHITE, P.C. 112 Baltimore Street Gettysburg, PA 17325 Dated: IUI Z 51,9Y Attorneys for Plaintiff ? o O ? a ? ? i l t l' C f ? p cn co AMIE G. TANNENBAUM, Plaintiff VS. PATRICIA BENDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-2029 CV CIVIL ACTION - LAW DEFENDANT'S RESPONSES TO THE PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS 1-2. See documents enclosed. Respectfully submitted, NEALON GOVER & PERRY By: ZL"'?4- Ca a Shore, Esquire I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: /d.2- o CERTIFICATE OF SERVICE AND NOW, thisI day of-dtmc, 2005, 1 hereby certify that I have served the foregoing RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Thomas R. Campbell, Esquire Campbell & White, P.C. 112 Baltimore Street Gettysburg, PA 17325 I Ca . Shore, Esquire _t. r • 2.Ai IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, Plaintiff, NO.: 04-2029 VS. PATRICIA BENDER, Defendant. : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this - day of July, 2006, I hereby certify that a copy of a Subpoena to Produce Documents or Things Pursuant to Rule 4009.22 was served on behalf of the Plaintiff in the above-captioned action on the person listed below in the manner indicated: Depositing in the U.S. Mail, at the Post Office at Gettysburg, Pennsylvania, certified mail, restricted delivery, return receipt requested, postage prepaid, to: Dr. Sanjiv H. Naidu, M.D., Ph.D. Hand & Upper Extremity Institute of Central PA Fredericksen Outpatient Center 2015 Technology Parkway Mechanicsburg, PA 17050 Dated: //26/ to Thomas R. C mpbell, Esquire Attorney I.D. No.: 75987 CAMPBELL & WHITE, P.C. 112 Baltimore Street Gettysburg, PA 17325 Telephone: (717) 334-9278 Attorneys for Plaintiff M1 1-3 r •• ru rR tI?FMNR?QU Ln p CarMW FM C3 ° (ECM p?Pkpay rw ? i m n, TOW POMP SFe g 7 M D HAND 6 UPPER PER N xs?- c flame 1. & Ind & Abo complete +i N Megicted Odymy Is deMnd. Aft par rwm red oddrM on the mWa I OW we ken Nt m the card to yom 06 aNi to the beck of the n*VS e. • M th9 fiord M specs pemols. I M&Ader alto: UVIV H NAIDU MD PhD NfiPD fi UPPER EXTREMITY INSTITU'. CENTRAL PA ,';1?iEEDERI(IKSEN- OUTPATIENT CENTER 2015 TECHNOLOGY PARKWAY MECHANICSBURG PA 17050 0325 a 2• ,aeder?.nds} 7004 2510 0005 4117 2717 (nrrAreem Ps Form 3811. Re?nksN' lOtIM Danskeo lMrn NSSSIet "www*lw tl?? i J ? el Ca aft r, r • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, Plaintiff, VS. PATRICIA BENDER, Defendant. NO.: 04-S-2029 JURY TRIAL DEMANDED HIGH-LOW SETTLEMENT AGREEMENT AND CASE MANAGEMENT STIPULATIONS THESE HIGH-LOW SETTLEMENT AGREEMENT AND CASE MANAGEMENT STIPULATIONS are entered into this 10? day of u fc 2001, by and between Plaintiff Amie G. Tannenbaum and AllState Insurance Company on behalf of itself and Defendant Patricia Bender, by and through their respective counsel. WHEREAS, on August 15, 2002, at approximately 3:45 o'clock P.M., Plaintiff Arnie G. Tannenbaum was operating her 1990 Toyota Camry in a northerly direction on South Third Street, in the Borough of Lemoyne, Cumberland County, Pennsylvania; and WHEREAS, at the same time and place, Defendant Patricia Bender was operating her 2000 Honda Accord in a westerly direction on Bossler Avenue; and WHEREAS, at that time and place, Defendant Patricia Bender failed to stop at the stop sign at the intersection of Bossler Avenue and South Third Street and drove through the stop sign in an attempt to cross South Third Street; and WHEREAS, at that time and place, the front driver side portion of Defendant Patricia Bender's car struck the front passenger side portion of Plaintiff's vehicle; and WHEREAS, subsequent to the aforementioned crash, Amie G. Tannenbaum instituted the above-captioned action against Patricia Bender; and WHEREAS, in the above-captioned matter, Arnie Tannenbaum has alleged, and Patricia Bender has denied, that Arnie Tannenbaum sustained injuries in the crash of August 15, 2002; and WHEREAS, AllState Insurance Company for itself, and on behalf of its insured, Patricia Bender, and Amie G. Tannenbaum, desire to enter into a stipulation as to liability for the cause of the crash and to submit the case to trial on the sole issues of whether Plaintiff Arnie Tannenbaum sustained injuries in the crash of August 15, 2002 and what amount of damages Arnie Tannenbaum sustained as a result; and WHEREAS, AllState Insurance Company, on behalf of itself and its insured -2- Patricia Bender, and Arnie G. Tannenbaum, desire to enter into a high-low settlement agreement, whereby AllState Insurance Company will pay the minimum amount of $30,000.00 to Arnie G. Tannenbaum, representing the low figure, within Fourteen (14) days from the date of this Agreement, and AllState Insurance Company and Patricia Bender's liability shall be capped at a high of $250,000.00, representing Patricia Bender's liability insurance limits. NOW, THEREFORE, in consideration of the mutual covenants contained herein, and with the foregoing incorporated by reference, and for good and valuable consideration, the parties agree as follows: 1. As soon as it is practical and convenient, and as soon as possible after the conclusion of the Depositions of the medical providers, the parties will submit the matter to trial in the Court of Common Pleas of Cumberland, Pennsylvania. 2. The parties agree that Defendant Patricia Bender was negligent in the operation of her motor vehicle and that her negligence was the sole cause of the crash of August 15, 2002; 3. The parties agree that Plaintiff Amie G. Tannenbaum was not negligent in causing the aforesaid crash. 4. The only issues to be submitted at trial are as follows: A. Was the crash of August 15, 2002 a factual cause of injury to Amie Tannenbaum? B. If so, what amount of damages has Plaintiff Amie G. Tannenbaum sustained as a result of the crash of August 15, 2002? 5. Despite obtaining an IME of Plaintiff by Dr. Sanjiv Naidu, the defense -3- will not be calling Dr. Naidu or any other physicians or persons as witnesses in this case. 6. The parties agree that the liability limits of the automobile insurance policy covering Patricia Bender on the date of the accident are $250,000.00. 7. The parties agree that $250,000.00 shall be the maximum recovery Arnie G. Tannenbaum can realize from AllState Insurance Company, and Patricia Bender. 8. Previously, A1lState Insurance Company has tendered an offer of $30,000.00 to settle the claims of Arnie G. Tannenbaum. The parties agree to establish $30,000.00 as the low or minimum recovery which Amie G. Tannenbaum shall realize. Said $30,000.00 sum shall be paid to Arnie G. Tannenbuam and Campbell & White, P.C., her attorneys, within Fourteen (14) days from the date of this Agreement. 9. If the Court finds that Arnie Tannenbaum has suffered injuries and damages in excess of $30,000.00 and enters judgment accordingly, the $30,000.00 paid to her shall be applied as a credit against that ultimate judgment amount. If the Court finds that Arnie Tannenbaum has not sustained any injuries or that her damages are in some amount less than $30,000.00, she will not be required to indemnify or reimburse to A1lState Insurance Company, Patricia Bender or any other entity, any portion of the $30,000.00 she receives; and the same sum is intended to be a guaranteed minimum recovery to Arnie G. Tannenbaum, regardless of any verdict in this case. 10. Plaintiff reserves her right to pursue any and all claims she may have for recovery of UIM benefits and nothing contained herein shall be considered a release of any of those claims. -4- Witness Witness CAMPBELL & WHITE, P.C. Thomas R. Cam ell, Esquire Attorney for Plaintiff NEALON, GOVER & PERRY R. Gover, Esquire for Defendant -5- 70, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, Plaintiffs, VS. PATRICIA BENDER, Defendants. NO.: 04-S-2029 JURY TRIAL DEMANDED NOTICE OF VIDEOTAPE DEPOSITION TO: Matthew R. Gover, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 PLEASE TAKE NOTICE that the video deposition of Francis X. Kilkelly, M.D., upon oral examination for the purpose of discovery and/or for use at trial, or for both purposes, will be taken at Hanover Orthopaedic Associates, Inc., located at 207 Blooming Grove Road, Hanover, Pennsylvania 17331, beginning at 1:00 o'clock P.M., on Thursday, March 27, 2008. The deposition shall be taken before Deborah L. Zepp, Zepp Court Reporting, CAMPBELL & WHITE ATTORNEYS AT LAW 112RALTDAMSRF8r GETTYSBURG, PRTdBY AMA 17325 rnM3344= who is authorized to render an oath, and a representative of Video Images, and shall continue until completed. The deposition is to be videotaped, pursuant to Pa. R.C.P. No. 4017. 1, by an employee of Video Images, and will be simultaneously recorded by stenographic means. The above-named is requested to bring all records, reports, letters, documents, memoranda, photographs, or other information or things not privileged which are relevant and material to the issues and subject matter involved in the above-captioned matter. CAMPBELL & WHITE, P.C. Thomas R. C pbell, Esquire I. D. #: 75978 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorneys for Plaintiffs Dated: D CAMPBELL & WHM -2 ATTORMYS AT LAW 112UFUKY XFRM Grrra8VMF?!U LVM"JZ25 (717)3U-nn ? Cam, -3 l-tn ? t ? ? PT' vx) PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ® for JURY trial at the next term of civil court. ? for trial without a jury. ------------------------------ CAPTION OF CASE (entire caption must be stated in full) (check one) Amie G. Tannenbaum, VS. Patricia 'Bender, VS. (PlaintiM (Defendant) ® Civil Action - Law ? Appeal from arbitration ? . - (other) The trial list will be called on and _ August 19, 2008 Trials commence on September 15, 2008 Pretriais will be held on August 27, 2008 (Briefs are due S days before pretriak No. 04-2029-CV Term Indicate the attorney who will try case for the party who files this praecipe: Thomas R. Campbell, Esquire Indicate trial counsel for other parties if known: Matthew R. Gover, Esquire This case is ready for trial. Signed: Print Name: Thomas R. Campbell Date: 6/2/08 Attorney for: Plaintiff W n C`7 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. AMIE G. TANNENBAUM, PATRICIA BENDER, Plaintiff, Defendant. . CIVIL ACTION - LAW NO.: 04-2029-CV MOTION TO WITHDRAW PRAECIPE FOR LISTING CASE FOR TRIAL TO: Curtis R. Long, Prothonotary AND NOW, this ` 7' day of June, 2008, comes Plaintiff, by her counsel, Thomas R. Campbell, Esquire, and hereby withdraws their Praecipe for Listing Case for Trial for the following reasons: 1. As per attached letter from Defendant's counsel, Matthew R. Gover, Esquire there is a conflict of scheduling as Defendant's counsel now is attached to a two week homicide trial in York County during the Cumberland County September Trial term by special Order of Judge Brillhart. 2. Also per letter it is agreed by the undersigned and Defendant's counsel that this case can be scheduled for the November 17, 2008 Trial term. Respectfully submitted, CAMPBELL & WHITE, P.C. - -/ - t-- /Z- q ? ?k? Thomas R. Ca ell, Esquire Attorney I.D. #: 75978 112 Baltimore Street CAMPBELL & WHITE ATTORNEYS AT LAW 1125ALMMORETIREU [)E19Y38URO,FZNNSY?VA Mms f11'n11KYA Gettysburg, PA 17325 // (717) 334-9278 Dated: ?/ Attorneys for Plaintiff F PRAFO'IPE FOR LbSTM CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PRO ONOTARY OF CUMBERLAND COUNTY PI list the following case: ® for JURY trial at the next term of civil court. ? for trial without a jury. CAPTION (awm em Amie G. CASE must be stated in fall) nbaum, (PlaintiM (check one) ® Civil Action - Law ? Appeal from arbitration (other) The trial M will be called on and October 21, 2008 Patricia indicate the a r (Defendant) Trials eommence on November 17, 2008 Preh'ials wgl be held on October 29, 2 008 (Briefs are due S days before pr&Webs No. 04-2029-CV Tenn torney who will try case for the party who files this praecipe: R. Campbell, Esquire Indicate trial counsel for other parties if known: ire This caw is rkady for trial. Signed: Print Name• o l o r Attorney for: Pa4p (C" + 1 4 C? 5-1 AMIE G. TANNENBAUM, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 04-2029 CIVIL PATRICIA BENDER, Defendant IN RE: PRETRIAL CONFERENCE Present at a pretrial conference held October 29, 2008, were Thomas R. Campbell, Esquire, attorney for the plaintiff, and Casey G. Shore, Esquire, attorney for the defendant. This case arises out of an intersection accident in which it is alleged that the defendant ran a stop sign. Liability for the accident is admitted and the defense does not dispute that the plaintiff was injured in the accident. The sole question is the amount of the damages. The trial of this case should be no more than one and one-half days in duration. The usual number of juror challenges will be exercised by the parties. October 29, 2008 Thomas R. Campbell, Esquire For the Plaintiff Casey G. Shore, Esquire For the Defendant Court Administrator Hess, J. Am ?'7 ^ JA -f I ! WV 6" 130 go oz 1. AMIE G. TANNENBAUM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 04-2029 CIVIL PATRICIA BENDER, Defendant VERDICT We, the jury, find in favor of the Plaintiff and against the Defendant in the amount of: Date: ?f p iZ 00? Foreperson: 00 CASE NO.: Cp COURTROOM NO.:? AM; e C . 7-a A gril rn Vs ? R d eA e DOCKET NO.: DI ` 00a5' DATE: /f - / 7- OF Juror # Name Random No. 1 40 DEMOSS, WAYNE -2136270295 w T? 3 15 DUPES, STEVEN R. -1813296839 Try 5 59 SAN, HUONG T. -1727192009 6 50 STONER, KYLE A. -1656865157 A?-- 8 53 WORLEY, KRISTIN E. -1425353439 9 35 TAYLOR, DOROTHY K. -1401506995 1(l 63 EPPLEY, AMY N -1396195917 1! 38- 9ANf& -5fk&qD* f , . - 12 22 CLUKEY, JEFFREY A. -978567925 13 l 11 A 15 M4 16 42 ER H -724275402 7r? 1 f 32 DROZDOWSKI, DUANE W -666960900 18 60 ASBURY, EDWARD D. -258422868 19 47 MAXWELL (POREMSKY), MICHELLE M. -82934075 20 65 NACE, LESLEE J 21703288 1 52 BERKHEIMER, CHASE W. 131300768 22 36 ----------------- KRIEBEL, JAMES ------- 137 -1 28 BROUGH, ANNA MARY 153171505 24 MILLER, JOHN E JR 490709309 y 12 YANOWSKI, CHERYL ANN 615164184 26 8 SMIT , REW A 692955994 2`7 62 KNIGHT, RO NE 759965114 28 55 ERNO, AMY T 799218894 29 37 TENAGLIA, CHRISTO EE 975920707 {1 31 ESLINGER, LA C. 1052552135 31 20 FRITZ, RUT 1175996117 32 17 SEILH ER, RONALD R. JR. 1432687878 3) 3 21 B DING, JOHN 1848103282 34 19 VALDEZ, CHRISTEN E 1855806116 3 5 EICHELBERGER, SHARON K. 115791 Monday, November 17, 2008 Page 1 of 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, Plaintiff, VS. PATRICIA BENDER, Defendant. TO: Ms. Patricia Bender c/o Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 Attorneys for Defendant NO.: 04-5-2029 JURY TRIAL DEMANDED NOTICE You are hereby notified to file a written answer to the attached motion for delay damages within twenty days from the filing of the motion or the delay damages sought in the motion may be added to the verdict or decision against you. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, Plaintiff, VS. PATRICIA BENDER, Defendant. : NO.: 04-5-2029 : JURY TRIAL DEMANDED PLAINTIFF'S MOTION FOR DELAY OF DAMAGES PURSUANT Pa. R.C.P. 238(c) Plaintiff Arnie G. Tannenbaum, by her undersigned counsel, moves this Court for delay damages pursuant to Pa. R.C.P. 238(c), and in support represents as follows: 1. Plaintiff initiated this action to recover monetary relief for bodily injuries by Writ of Summons dated May 5, 2004. 2. Said Writ of Summons was served on Defendant, Patricia Bender by Cumberland County Sheriff on May 20, 2004. 3. The jury rendered its verdict in this action on November 18, 2008. 4. The verdict was for Plaintiff and against Defendant, Patricia Bender in the amount of Ninety-Five Thousand Two Hundred Forty-Seven Dollars (95,247.00). 5. Delay damages began to accrue as of May 20, 2005, one (1) year after original process was first served in this action. 6. The amount in computation in delay damages which Plaintiff requests are as follows: 2005: ($95,247.00) (6.25%) (225 - 365) _ $3,669.62 2006: ($95,247.00) (8.25%) _ $7,857.88 2007: ($95,247.00) (9.25%) _ $8,810.35 2008: ($95,247.00) (8.25%) (323 _ 365) _ $6,953.69 7. The total calculation of delay damages due is as follows: 2005 - $3,669.62 2006 - $7,857.88 2007 - $8,810.35 2008 - $6,953.69 Total Delay Damages Due: $27,291.54 8. Defense Attorney Casey Shore has reviewed these calculations and is not opposed to entry of delay damages as requested. WHEREFORE, Plaintiff Arnie G. Tannenbaum respectfully requests that this Honorable Court enter an Order adding delay damages in the amount of $27,291.54 to the verdict in this case, bringing the total award due to Plaintiff to $122,538.54. Dated: Aq 3 ks/ Thomas R. Ca bell, Esquire Attorney I.D. No.: 75987 CAMPBELL & WHITE, P.C. 112 Baltimore Street Gettysburg, PA 17325 Telephone: (717) 334-9278 Attorneys for Plaintiff -2- r-a .d cxz C -D r?,z 'ta ?Y - . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AMIE G. TANNENBAUM, : NO.: 04-S-2029 Plaintiff, VS. PATRICIA BENDER, Defendant. PRA- TO: Curtis R. Long, Prothonotary Please mark the above-captioned action discontinued and satisfied with prejudice. Respectfully submitted, CAMPBELL & WHITE, P. C. 7 Thomas R. C pbell, Esquire Attorney I.D. #: 75978 112 Baltimore Street Gettysburg, PA 17325 (717) 334-9278 Attorneys for Plaintiff Dated: a 9 CAWBELL & WHITE ATTORNEYS AT LAW 112n TftA0nF wxr OEITYSB G, P!21WLVA 17323 (717)33 z & ?? N f ? `? -rv~ p fib,' ??, ? ? ._. -i ? ."w7 '"?'