HomeMy WebLinkAbout09-21-04 CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENas::<,
PURSUANT TO RULE 4009.22
21
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED
-VS- CASE NO: 21-03-936
N/A
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of R. MARK THOMAS, 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 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) The parties have waived the twenty-day notice provided in
Rules 4009.21 and 4009.22 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, A
DATE: 09/01/2004 Rr'. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
DE12-232670 6 3 95 5 --LO 1
717 243 6486
717-243-6406 SAIDIS SHUFF FLOWER 866 PO1 SEP 13 '04 10:52
, HEMI-I&3SD7 6 3 9 5 5 -- C 0 1
! 'd I%,%,~'b,~LTL Aq-lIl pum A]~]*~ mt9 :GO 90 ~I claS
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ORP CRT.
IN THE MATTER OF: COURT 0F COMMON PLEAS
ELEANOR U. C00LIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
NOTICE OF INTENT TO S~RVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
GREEN RIDGE VILLAGE OTHER
CHAMBERSBURG HOSPITAL MEDICAL RECORDS
J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS
JOSEPH F. BRAZEL, M.D MEDICAL RECORDS
JAMES HEGARTY, M.D. MEDICAL RECORDS
CARLISLE HOSPITAL OTHER
TO: ROBERT M. FREY
JAMES D. FLOWERS, JR.
MCS on behalf of R. MARK THOMAS, 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: 09/01/2004
MCS on behalf of
R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
CC: R. MARK THOMAS, ESQ. -
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#8O0
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-277318 63 95 5 --CO 2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN RE: ESTATE OF :
: ESTATE NO. 21-03-936
:
ELEANOR U. COLLIDGE, DECEASED :
:
:
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
TO: CUSTODIAN 0¥ RECOYJ)S FOR: GREEN RIDGE VILLAGE
(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
At MCS GROUP INC,, 1601 MARKET STREET ~IITTE 8f~D P~iTI.AT~RT.P~TA PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable cost of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court order compelling you
to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: R. MARK THOMAS. ESQ.
ADDRESS: 101 s. MARKET gTREET
MECHANICSBURG PA 170~
TELEPHONE: (215) 246-oq(]D
SUPREME COURT ID #
ATTORNEY FOR: PLAINTIFF
BY THE COURT:
L..
REGISTER-OF~WILLs/CLERK OF ORPI~A[~s~ COL~T
SEP 1 § 200
0 DEPUTY
Date:
Seal of the Court
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
GREEN RIDGE VILLAGE
210 BIG SPRING ROAD
NEWVILLE, PA 17241
RE: 63955
ELEANOR IJ. COOLIDG~ECEASED)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
ANY AND ALL RECORDS.
Subject: ELEANOR U. COOLIDGE(DECEASED)
SU10-521718 6 3 95 5 --LO 1
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSU~ TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of R. MARK THOMAS, 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-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) The parties have waived the twenty-day notice provided in
Rules 4009.21 and 4009.22 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: 09/01/2004 R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
DE12-232671 6 3 9 5 5 --LO 2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ORP CRT_
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. C00LIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
NOTICE OF ~ TO SERVE A SUBPOENA TO PRODUCE ~S AND
· ~{INGS FOR DISC-~)%i]~RY PURS~ TO R~ 4009.21
GREEN RIDGE VILLAGE OTHER
CHAMBERSBURG HOSPITAL MEDICAL RECORDS
J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS
JOSEPH F. BRAZEL, M.D MEDICAL RECORDS
JAMES HEGARTY, M.D. MEDICAL RECORDS
CARLISLE HOSPITAL OTHER
TO: JAMES D. FLOWERS, JR.
ROBERT M. FREY
MCS on behalf of R. MARK THOMAS, 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: 09/01/2004
MCS on behalf of
R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
CC: R. MARE THOMAS, ESQ. -
questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#80O
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-277317 6 3 95 5 --CO 1
COMMONWEALTH Of PENNSYLVANIA
COUNTY Of CUMBERLAND
IN RE: ESTATE OF ·
· ESTATE NO. 21-03-936
ELEANOR U. COLLIDGE, DECEASED '
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG I-I(3.RPTTAT,
(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
At MCS GROUP INC., 1601 MARKET STREET SUTIE 800 PHILADELPHIA PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above· You have the right to seek in advance the reasonable cost of preparing the
copies or producing the things sought·
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court order compelling you
to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: R. MARK THOMAS. ESQ.
ADDRESS: 101 S. MARKET ST.
MECHANTC,,gBIIRC. PA I 7f)qq
TELEPHONE: (2150 246-0900
SUPREME COURT ID #
ATTORNEY FOR: ?LAINTIFF
BY THE COURT:
REGIST[ER OF MILLS/CLERK OP (~RPHANS' COUR(~J
SEP 15 200
~ (J DEPUTY
Date:
Seal of the Court
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODI/flV OF RECORDS FOR:
CI-IAMBERSBURG HOSPITAL
PSYCHIATRIC UNIT
112 N. TI'H STRE~
CHAMBERSBURG, PA 17201
RE: 63955
EI.I~.ANOR U. COOLIDGE(DECEASED)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
ANY AND ALL RECORDS FROM 01/01/1999 TO PRESENT.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for aH other providers.
~ntire hospital medical file, including but not limited to any and all records,
correspondence to ired/zorn tim consulting and/or treating physician, files,
memo~ handwritten notes, history and physical reports, medication/
prescription records, nurse's notes, doctor's comments, dietary restrictions,
and all patient consent or refi_,~l of treatment, procedures, test, and/or
medication, lab and diagnostic tea 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, dia_onosis, care, treatment,
admission, discharge, or emergency care pertaining to:
Dates Requested: up to and indudi~ the present.
Subject: EI.EANOR U. COOLII~E(D~_,CEASlgD)
5U10-521720 63)5 5--T-O 2
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
AS a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of R. MARK THOMAS, 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 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) The parties have waived %he twenty-day notice provided in
Rules 4009.21 and 4009.22 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: 09/01/2004 R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
DE12-232672 6 3 9 5 5 --LO 3
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ORP CRT_
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
NOTICE OF IN~'ENT TO SERVE A SUBPOENA TO PRODUCE D~S AND
THINGS FOR DISCO%~RY PURSU2%/TT TO RULE 4009.21
GREEN RIDGE VILLAGE OTHER
CHAMBERSBURG HOSPITAL MEDICAL RECORDS
J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS
JOSEPH F. BRAZEL, M.D MEDICAL RECORDS
JAMES HEGARTY, M.D. MEDICAL RECORDS
CARLISLE HOSPITAL OTHER
TO: JAMES D. FLOWERS, JR.
ROBERT M. FREY
MCS on behalf of R. MARK THOMAS, 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: 09/01/2004
MCS on behalf of
R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
CC: R. MARK THOMAS, ESQ. -
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#80O
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-277317 6 3 9 5 5 --CO 1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN RE: ESTATE OF :
: ESTATE NO. 21-03-9;~6
:
ELEANOR U. COLLIDGE, DECEASED :
:
:
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
TO: CUSTODIAN OF RECORDS FOR: J. CRAIG JURGENSEN. 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
At MCS GROUP INC., 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable cost of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court order compelling you
to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: R. MARK THOMAS~ ESQ.
ADDRESS: 101 S. MARKET STREET
MECHANICSBURG PA 17053
TELEPHONE: (2150 246-0q~
SUPREME COURT ID #
ATTORNEY FOR: PLAINTIFF
BY THE COURT:
REGISTER OF WILLS/CLERK-Or ORPHANS' COURT
SEP 1 § 2004 ^_' G.
() -- DEPUTY
Date:
Seal of the Court
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECO~S FOR:
J. CRAIG JURGENSEN, M.D.
850 WALNUT BOTTOM ROAD
BELVEDERE MED'L CTR.
CARLISLE, PA 17013
RE: 63955
ELEANOR U. COOLIDGE(DECEASED)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
dia~osis or treatment pertaining to:
Dates Requested: up to and including the present.
Subject: EI.EANOR U. COOLIDGE(DECEASED)
SU10-521722 6 3 95 5 --LO 3
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
AS a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of R. MARK THOMAS, 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 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) The parties have waived the twenty-day notice provided in
Rules 4009.21 and 4009.22 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: 09/01/2004 R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
DE12-232673 6 3 9 5 5 --LO 4
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ORP CRT.
IN THE MATTER 0F: COURT 0F COMMON PLEAS
ELEANOR U. C00LIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
GREEN RIDGE VILLAGE OTHER
CHAMBERSBURG HOSPITAL MEDICAL RECORDS
J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS
JOSEPH F. BRAZEL, M.D MEDICAL RECORDS
JAMES HEGARTY, M.D. MEDICAL RECORDS
CARLISLE HOSPITAL OTHER
TO: JAMES D. FLOWERS, JR.
ROBERT M. FREY
MCS on behalf of R. MARK THOMAS, 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: 09/01/2004
MCS on behalf of
R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
CC: R. MARK THOMAS, ESQ. -
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHII~ELPHIA, PA 19103
(215) 246-0900
DE02-277317 63 9 5 5--CO 1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN RE: ESTATE OF :
ESTATE NO. 21-03-q36
:
ELEANOR U. COLLIDGE, DECEASED :
:
:
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
TO: CUSTODIAN OF RECORD~ FOR; JOSEPH F. BRAZET.: M.T~.
(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
At MCS GROUP INC., 1601 MARKET STREET SUITE 800 PHTLADET,PHTA PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable cost of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court order compelling you
to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: g. MARK THOMAS, ESQ.
ADDRESS: 101 S. MARKET STREET
MECHANICSBURG PA 17055
TELEPHONE: (21 50 ?A6-nqnn
SUPREME COURT ID #
ATTORNEY FOR: PT,ATNTT'PF
BY THE COURT:
REGISTER (~F WILLS/CLERK OF ORPHA~IS' C~]~R'I'-
6EPU '
Date:
Seal of the Court
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
JOSEPH F. BRAZEL, M.D
220 WILSON STREET
CARLISLE, PA 17013
RE: 63955
ELEANOR Il. COOLIDGE(DECEASED)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
ANY AND ALL RECORDS FROM 01/01/1989 TO PRESENT.
Entire medical file, including but not limited to any and all records,
correspondence to and from the consulting and treating physicians, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, including any and all such items as may be stored in a
computer database or otherwise in electronic form, relating to any examination,
diagnosis or treatmem pertaining to:
Dates Requested: up to and including the present.
Subject: ELi~.ANOR U. COOLII~E0)ECEASED)
SU10-521724 63 955--L04
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
AS a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of R. MARK THOMAS, 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 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) The parties have waived the twenty-day notice provided in
Rules 4009.21 and 4009.22 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: 09/01/2004 R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
DE12-232674 6 3 9 5 5 --LO 5
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ORP CRT.
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT 'PO RULE 4009.21
GREEN RIDGE VILLAGE OTHER
CHAMBERSBURG HOSPITAL MEDICAL RECORDS
J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS
JOSEPH F. BRAZEL, M.D MEDICAL RECORDS
JAMES HEGARTY, M.D. MEDICAL RECORDS
CARLISLE HOSPITAL OTHER
TO: JAMES D. FLOWERS, JR.
ROBERT M. FREY
MCS on behalf of R. MARK THOMAS, 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: 09/01/2004
MCS on behalf of
R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
CC: R. MARK THOMAS, ESQ. -
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-277317 6 3 9 5 5 --CO 1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN RE: ESTATE OF :
: ESTATE NO. ?l-o'~-~)~
:
ELEANOR U. COLLIDGE. DECEASED :
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
TO: CUSTODIAN OF RECORDS FOR: JAMES HEGARTY, 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
At MCS GROUP INC., 1601 MARKET STREET SUITE 800 PHILADLEPHIA PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable cost of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court order compelling you
to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: R. MARK THOMAS~ ESQ.
ADDRESS: 101 S. MARKET STREET
MECHANICSBURG PA 17055
TELEPHONE: (2150 246-0900
SUPREME COURT ID #
ATTORNEY FOR: PLAINTIFF
BY THE COURT:
ORPHANS' COURT
DEPUTY
Date:
Seal of the Court
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
JAMES HEGARTY, M.D.
176 S. COLDBROOK AVENUE
CHAMBERSBIJRG, PA 17201
RE: 63955
ELEANOR U. COOLIDGE(DF~EASED)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical file, includin~ but not limited to any and all records,
correspondence to and from the consulting and treating physician~, files,
memoranda, hmxlwritten notes, history and physical reports, _medication/
prescription records, including any and all such items as may be stored in a
computer d:.abase or otherwise in electronic form, relating to any examination,
diagnosis or treatment pe~ to:
Dates Requested: up to and including the present.
Subject: EL~.ANOR U. COOLIDGE(DECEASED)
SU10-521726 63 95 5 --LO 5
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUi~ TO RULE 400).22
IN THE MATTER OF: COURT OF COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
AS a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of R. MARK THOMAS, 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 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) The parties have waived the twenty-day notice provided in
Rules 4009.21 and 4009.22 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 09/01/2004 R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
DE12-232675 63 95 5 --LO 6
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ORP CRT.
IN THE MATTER OF: COURT 0F COMMON PLEAS
ELEANOR U. COOLIDGE, DECEASED TERM,
-VS- CASE NO: 21-03-936
N/A
NOTICR OF I1TTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THII~GS FOR DISCO%/ERY PURSUANT TO RULE 4009.21
GREEN RIDGE VILLAGE OTHER
CHAMBERSBURG HOSPITAL MEDICAL RECORDS
J. CRAIG JURGENSEN, M.D. MEDICAL RECORDS
JOSEPH F. BRAZEL, M.D MEDICAL RECORDS
JAMES HEGARTY, M.D. MEDICAL RECORDS
CARLISLE HOSPITAL OTHER
TO: JAMES D. FLOWERS, JR.
ROBERT M. FREY
MCS on behalf of R. MARK THOMAS, 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: 09/01/2004
MCS on behalf of
R. MARK THOMAS, ESQ.
Attorney for PLAINTIFF
CC: R. MARK THOMAS, ESQ. -
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-277317 6 3 95 5 --CO 1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN RE: ESTATE OF :
ESTATE NO. 21-03-936
:
ELEANOR U. COLLIDGE. DECEASED :
:
:
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
TO: CUSTODIAN OF RECORDS FOR: CARLISLE 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
At MCS GROUP INC., 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable cost of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court order compelling you
to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: R. MARK THOMAS, ESQ.
ADDRESS: 101 S. MARKET STREET
MECHANTCSBURG PA 17055
TELEPHONE: ¢215) 246-0900
SUPREME COURT ID #
ATTORNEY FOR: PT.~,TNTTFF
BY THE COURT: ,5
REGISTER OF WILLS/CLERK OF ORPHANS' COURTLq
DEPUTY
Date:
Seal of the Court
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RF~ORDS FOR:
CARLISLE HOSPITAL
246 PARKER STREET
CARLISLE, PA 17013
RE: 63955
ELEANOR LI. COOLIDGE(DECEASED)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
ANY AND ALL RECORDS FROM 01/01/1989 TO PRESENT.
Subject: ELEANOR U. COOLIDGE(DECEASED)
SU10-521728 6 3 95 5--LO 6