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HomeMy WebLinkAbout00-05007?. Identification No. 26718 11th Floor 230 South Broad Street Philadelphia, PA 19102 (215) 735-3326 MYCHAK GECKLE & WELKER, P.C. By: Patrick G. Geckle Attorneys at Law Attorneys for Plaintiff NEIL WAGER 2.20 Wood Street Camp Hill, PA 17011 Vs. BIN S. LI 4968 Erbs Bridge Road Mechanicsburg, PA 17055 and ZHENG WEI BAI 4968 Erbs Bridge Road Mechanicsburg, PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. Ud ""S(.5G7 C.1U6? I CIVIL ACTION NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages. you must take action within. twenty (201 days after this complaint and notice are served. by entering a written appearance personally or by attorney and filing in wnbng with the court your defenses or objections to the claims set forth against you. You are wemed that d you fail to do so the case may proceed without you and a Judgment may be entered against you by the court without further notice Iw any money. claimed at the complaint or for any other claim or relief requested by the plaintlH. You may lose money o property w other nghts important to you. YOU SHOULD. TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT. HAVE A LAWYER OR CAN NOTAFFOROONE GO TOOR TELEPHONE THE OFF;CE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP ;arlis , PA (717,Y240-62 5unty Court House Square AVISO Le hen demandado s usted an la Corte. Si usted quie,re de fenderse de estas demandas espuestas an las pagmas slguientes. usted tiene vemte (20) dia}} de plazo al partu de Ia fecha de la demanda y la notificacrdn Mace falta asentar una comparenca escrrta o an persona o con un abogado y entregar a to cone on forma escnta sus defenses c sus obleciones a Las demendas en contra de su persona. Sea avisado que si usted no fa defiende. to torte tomars medidas y puede conhnyar la demanda an contra suya sin previo oviso o notificaerbn. Adem s. Le torte puede deudir a favor del demandante v requiere que usted cumpla con todas las provisions de esta demanda Usted puede perder dinero o sus prupredades u coos derechos rmportantes We :sited. LLEVE ESTA DEMANDA A UN ASOGAOO INMEDIATA. MENTE SI NO TIENE ABOGADO 0 SI NO TIENE EL )IN ERO SUFICIENTE DE PAGAR TqL SERVICO VAYA EN -PERSONA 0 LL9ME FOR TELEFONO A LA OFICtNA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA-JO PARA AVERIGUAR DONDE Se PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County ?cc? ??iLQcracrt?rcPV Carlisle, PA 17013-3387 (?rzoo- o7Y9-d!?` MYCHAR GECRLE 8 WELKER, P.C. By: Patrick G. Geckle Attorneys at Law Identification No. 26718 11th Floor 230 South Broad Street Philadelphia, PA 19102 (215) 735-3326 Attorneys for Plaintiff NEIL WAGER 220 Wood Street Camp Hill, PA 17011 VS. BIN S. LI 4968 Erbs Bridge Road Mechanicsburg, PA 17055 and ZHENG WEI BAI 4968 Erbs Bridge Road Mechanicsburg, PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 60- 500'7 CIVIL ACTION 1. The Plaintiff, NEIL WAGER, is an adult individual residing at 220 Wood Street, in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania. 2. The Defendant, BIN S. LI, is an adult individual residing at 4968 Erbs Bridge Road, Township of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania. 3. The Defendant, ZHENG WEI BAI, is an adult individual residing at 4968 Erbs Bridge Road, Township of Mechanicsburg, County of Cumberland , Commonwealth of Pennsylvania. COUNT I. NEIL WAGER VS. BIN S. LI and ZHENG WEI BAI 4. Plaintiff, NEIL WAGER, incorporates paragraphs 1 through 3 above as fully as though the same were hereinafter set forth at length. 5. On or about July 26, 1998, Plaintiff, NEIL WAGER, was lawfully operating his motor vehicle eastbound exiting at Super Petz at Hampden Mall (Carlisle Pike and Hampden Center), Hampden Township, Cumberland County, Commonwealth of Pennsylvania, when suddenly and without warning the motor vehicle owned by Defendants, BIN S. LI and ZHENG WEI BAI, and operated by Defendant, BIN S. LI, ran through a red light and violently struck Plaintiff's vehicle causing serious injuries to Plaintiff hereinafter referred to. 6. Solely as a result of the aforesaid accident, the Plaintiff suffered serious physical injuries, including without limitation, left cervical strain and sprain, radiculopathy, left trapezius strain, subluxation of AC joint, post-traumatic left shoulder girdle bursitis with AC joint pain, cervicothoracic strain and myofascial pain with a trigger point, thoracic spine pain, tear of rotator cuff with two rotator cuff impingement syndrome left shoulder with separation of AC joint requiring surgerical repair of tear of left rotator cuff all of which may be permanent in nature, cause permanent disfigurement and/or loss of use of a bodily function and may have aggravated pre-existing 2 conditions. 7. Further, Plaintiff incurred a severe shock to his nerves and nervous system, great physical pain and mental anguish and was prevented from attending to his usual duties, activities, and avocations all of which may continue for an indefinite time in the near future. 8. This action resulted solely from the negligence and recklessness of the Defendants herein and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiff. 9. The negligence and recklessness of the Defendants consisted of the following: a. Failure to properly operate and control their motor vehicle; b. Driving at an excessive rate of speed under the circumstances; C. Failure to keep a proper lookout; d. Failure to regard the point and position of the other motor vehicle then and there being lawfully operated upon said highway; e. Failure to avoid striking another motor vehicle; f. Failure to keep constant vigilance of the road, traffic, weather, and road conditions; 3 g. Violation of the Statutes of the Commonwealth of Pennsylvania, as well as the Ordinances of Cumberland County governing the operations of motor vehicles on the streets and highways; h. Failure to obey traffic signal; i. Wanton and reckless disregard for the rights and safety of the Plaintiff; j. Failure to use due care under the circumstances; k. Negligence and recklessness at law. 10. As a result of this accident, the Plaintiff will be obliged to receive and undergo medical attention and care and to expend various sums of money or to incur various expenses and he may be obliged to continue to expend such sums and to incur such expenditures for an indefinite period of time in the future. 11. As a further result of this accident, Plaintiff has or may suffer a severe loss of his earnings, and impairment of his earning capacity or power. 12. As a further result of this accident, Plaintiff has suffered severe physical pain, mental anguish, and humiliation and he may continue to suffer same for an indefinite time in the future. 13. As a direct and reasonable result of this accident aforementioned, Plaintiff has or may hereafter 4 incur other financial expenses or losses which do or may exceed amount which he may otherwise be entitled to recover. , Plaintiff demand damages of Defendants herein, individually, collectively, jointly and severally, for a sum in excess of Fifty Thousand Dollars ($50,000.00), plus costs, delay damages, and interest on each count. MYCHAK GECKLLEE & WELKER, P.C. By: P ick G. Geckle, Attorneys for Plaintiff 5 } V E R I F I C A T I O N COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF CUMBERLAND Neil Wager being duly sworn according to law, deposes and says that he is the plaintiff in the within matter and that the facts set forth in.the foregoing Civil Action are true and correct to the best of his knowledge, information, and belief, and that this statement is made subject to the penalties of 18 PA C.S. 4940, relating to unsworn falsifications to authorities. /-- Neil W er I r? P c? C T !'T. ?C L_ M e? On (.7 l; 0 t SHERIFF'S RETURN - REGULAR a CASE NO: 2000-05007 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAGER NEIL VS LI BIN S ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE LI BIN S DEFENDANT was served upon the , at 0019:50 HOURS, on the 25th day of July , 2000 at 4968 ERBS BRIDGE ROAD MECHANICSBURG, PA 17055 BIN S. LI by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.06 Affidavit .00 Surcharge 10.00 .00 36.06 Sworn and Subscribed to before me this jee day of -Idsa o2 A. D. Prothonotary So Answers: R. Thomas Kline 07/26/2000 MYCHECK, GECKLE & WELKER By: 3 F?R.ZY- ? tT'Yl Deputy Sheriff SHERIFF'S RETURN - REGULAR ' CASE NO: 2000-05007 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAGER NEIL VS LI BIN S ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE BAI DEFENDANT was served upon the , at 0019:50 HOURS, on the 25th day of July , 2000 at 4968 ERBS BRIDGE ROAD MECHANICSBURG, PA 17055 by handing to BIN S. LI a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ALL day of 02rpo A.D. "Piwothonotary So Answers: R. Thomas Kline 07/26/2000 MYCHECK, GECKLE & WELKER pQ By: ((KLJq" I (a _ -Q-?. Deputy Sheriff NEIL WAGNER Plaintiff V. BIN S. LI, and, ZHENG WEI BAI, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 00-5007 CIVIL TERM JURY TRIAL DEMANDED TO THE PROTHONOTARY: r Please enter the undersigned's appearance on behalf of the Defendants, Bin S. Li and Zheng Wei Bai, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER By: ChristopN er . Knight, Esquire Atty. I.D. #80058 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 31 st day of July, 2000, 1 hereby certify that I have served the foregoing Praecipe entering my appearance on the following via first class mail, addressed to: Patrick G. Geckle, Esquire MYCHAK, GECKLE & WELKER, P.C. 11th Floor 230 South Front Street Philadelphia, PA 19102 19, Christo er J. Knight, Esquire Dated: July 31, 2000 NEIL WAGNER Plaintiff V. BIN S. LI, and, ZHENG WEI BAI, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 00-5007 CIVIL TERM JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Neil Wagner, and his counsel Patrick G. Geckle, Esquire MYCHAK, GECKLE & WELKER, P.C. 11th Floor 230 South Front Street Philadelphia, PA 19102 YOU ARE HEREBY NOTIFIED, that the New Matter set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GOVER By: David J. Freed, Esquire Atty. I.D. #76622 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 NEIL WAGNER Plaintiff V. BIN S. LI, and, ZHENG WEI BAI, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW NO. 00-5007 CIVIL TERM JURY TRIAL DEMANDED ANSWER TO COMPLAINT AND NEW MATTER AND NOW, comes the Defendants, Bin S. Li and Zheng Wei Bai, by and through their attorneys, Nealon & Gover, P.C., and in support of their Answer aver as follows: 1. Admitted, upon information and belief. 2. Admitted. 3. Admitted. 4. Paragraphs 1 through 3 are incorporated herein by reference. 5. Admitted in part and denied in part. It is admitted that Plaintiff and Defendant, Bin S. Li, were involved in a motor vehicle accident at the place and at the date and time alleged. Furthermore, it is admitted that the vehicle operated by Defendant Li is owned by Defendant Li and Defendant Bai. To the extent that this paragraph contains other allegations, the same are denied pursuant to Pa. R.C.P. 1029(e). 6-7. Following reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of these paragraphs and proof is demanded at trial. 8-9. These paragraphs represent conclusions of law to which no responsive pleading is required. To the extent that they allege facts, the same are denied pursuant to Pa. R.C.P. 1029(e). 10-13. Following reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the matters asserted in these paragraphs and proof is demanded at trial. NEW MATTER 14. Paragraphs 1 through 13 of this Answer are incorporated herein by reference. 15. Defendants Li and Bai are husband and wife. 16. The vehicle operated by Li on the date and time alleged herein is owned by Li and Bai, however, on the date of the accident was being operated only by Li. 17. Defendant Bai was not in the car. 18. Defendant Bai is not a proper party to this lawsuit. WHEREFORE, Defendants Bin S. Li and Zheng Wei Bai respectfully request that the Complaint against them be dismissed. Respectfully submitted, NEALON & GOVER By:}4IL9. David J. Freed, Esquire Atty. I.D. #76622 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 I, Bin S. Li, verify that the statements made in the foregoing Answer 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. Bin S. Li Dated: 8/9/00 VERIFICATION I, Zheng Wei Bai, verify that the statements made in the foregoing Answer to the Complaint and 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. Dated: G(&?, IS' .2o? Zheng Wei Bai CERTIFICATE OF SERVICE AND NOW, this 22nd day of August, 2000, 1 hereby certify that I have served the foregoing Answer to the Complaint and New Matter on the following via first class mail, addressed to: Patrick G. Geckle, Esquire MYCHAK, GECKLE & WELKER, P.C. 11th Floor 230 South Front Street Philadelphia, PA 19102 David J. Freed, Esquire T^ ; NEIL WAGNER Plaintiff V. BIN S. LI, and, ZHENG WEI BAI, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 00-5007 CIVIL TERM JURY TRIAL DEMANDED TO THE PROTHONOTARY: PRAMPF Please enter the undersigned's appearance on behalf of the Defendants, Bin S. Li and Zheng Wei Bai, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER By: ? , m-K David J.Freed, Esquire Atty. I.D. #76622 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 CERTIFICATE OF SERVICE r AND NOW, this 22nd day of August, 2000, 1 hereby certify that I have served the foregoing Praecipe entering my appearance on the following via first class mail, addressed to: Patrick G. Geckle, Esquire MYCHAK, GECKLE & WELKER, P.C. 11th Floor 230 South Front Street Philadelphia, PA 19102 David J. Freed, Esquire Dated: August 22, 2000 NEIL WAGNER Plaintiff V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Defendants, Bin S. Li and Zheng Wei Bai, certify that: 1. A Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each parry. 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. 4. The Subpoena which will be served is identical to the Subpoena which is attached to the Notice of Intent to Serve the Subpoena. n I Cp' In '? ,, n DATE: 08/28/01 b-6c 19rian N. Zulli, Esquire Atty. I.D. #85948 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Attorney for Defendants, Bin S. Li and Zheng Wei Bai NEIL WAGNER Plaintiff V. BIN S. LI, and, ZHENG WEI BAI, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 00-5007 CIVIL TERM : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants, Bin S. Li and Zheng Wei Bai, intend to serve Subpoenas identical to the ones that are 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 Subpoenas. If no objection is made the Subpoenas may be served. Respectfully submitted, NEALON & GOVER, P.C. By: Brian . Z Ili, Esquire Atty. I.D. #85948 2411 North Front Street Harrisburg, PA 17110 Date: 08/06/01 (717) 232-9900 Attorney for Defendants, Bin S. Li and Zheng Wei Bai NEIL WAGNER Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Jerome Korinkchak, M.D. Green Hill Family Health Center 503 Bridge Street New Cumberland, PA 17070 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981: 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: d(jl DATED: PROTHONOTARY Seal of the Court C;P7?L0U' f NEIL WAGNER Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Smith Radiology 1515 Bridge Street New Cumberland, PA 17070 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street - Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: %a2 /? DATED:Gco I PROTHONOTARY Seal of the Court E, NEIL WAGNER Plaintiff V. BIN S. LI, and, ZHENG WEI BAI, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 00-5007 CIVIL TERM JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Healthsouth Rehab of Mechanicsburg P.O. Box 2016 Mechanicsburg, PA 17055 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. ,2411 North Front Street - Harrisburg, PA 17110 717-232-9900 Attorney for Defendant DATED: Af4aco Seal of the Court BY THE COURT: T NEIL WAGNER Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Healthsouth Rehab of New Cumberland 503 Bridge Street New Cumberland, PA 17070 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15169 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: h K.ts Seal of the Court PROTHONOTARY ?7 NEIL WAGNER Plaintiff V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Stuart A. Hartman, D.O. 2645 North Third Street, Suite 490 Harrisburg, PA 17110 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulff, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: o? ( . DATED: PROTHONOTARY Seal of the Court C NEIL WAGNER Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CPAL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Penn State Geisinger Health System ATTENTION: MEDICAL RECORDS P.O. Box 850 Hershey, PA 17033 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant DATED: AzUdI Seal of the Court BY THE COURT: PROTHONOTARY ?j'J - NEIL WAGNER Plaintiff V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Melodie A. Adinolfi, LMT and Associates 716 State Street Lemoyne, PA 17043 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. -2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: - Q PROTHONOTARYCl? Seal of the Court l NEIL WAGNER IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Central PA MRI Center P.O.Box 8500-8495 Philadelphia, PA 19178 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street - Harrisburg, PA ,17110 717-232-9900 Attorney for Defendant n BY THE COURT: DATED: N PROTHONOTARY Seal of the Court NEIL WAGNER Plaintiff V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Thomas A. Malin, M.D. Orthopedic Surgeons of Central Pennsylvania 99 November Drive Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & COVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant DATED: I Seal of the Court BY THE COURT: C PI ONOT Q /1 n ?. n rD n.lYt. NEIL WAGNER Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZIIENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital 503 North 21st Street Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & COVER, P.C. 2411 North Front Street -Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: PROTHONOTARY Seal of the Court NEIL WAGNER Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Magnetic Imaging Center 4665 Trindle Road Mechanicsburg, PA 17055 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Neil J. Wagner, Date of Birth 07/15/69 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street - Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: I Seal of the Court NEIL WAGNER Plaintiff V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW BIN S. LI, and, NO. 00-5007 CIVIL TERM ZHENG WEI BAI, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Berg Electronics, Inc. Emig at Busser Road P.O. Box 248 Emigsville, PA 17318-0248 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110. Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, workers compensation records, payroll records or other documents pertaining to Neil 7. Wagner, Date of Birth 07/15169 and Social Security No. 601-16-7981. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED:A? / Seal of the Court PROTHONOTARY I CERTIFICATE OF SERVICE AND NOW, this 28"' day of August, 2001, I hereby certify that I have served the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Patrick G. Geckle, Esquire MYCHAK, GECKLE & WELKER, P.C. 230 South Front Street, 11 "Floor Philadelphia, PA 19102 `?v.Q,Q;c Rr an N. Zulli, Esquire ry f ??_ l _ II - i- } ;_,_, -- ? r - - - _ ° _ = ; - .. -tii' '! ? a? ". ._ -? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS NEIL WAGER TERM, -VS- CASE NO: 00-5007 LI, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07115/2002 ?CSt .o-nbeh?/lf of BRIAN N,/.//n?$UE IESQ, ? Attorney for DEFENDANT DE11-345247 783L3_2_-I_-02- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NEIL WAGER VS LI File No. 00-5007 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: RICHARD J. PATTERSON (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 ST., X1800, PHILA., 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: BRIAN N. ZULLI, ESQ. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID #- ATTORNEY FOR. DEFENDANT DATE-, L-?E Y,.266;? Seal of the Court rr..' iEff. 7J97y EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RICHARD J. PATTERSON 875 POPLAR CHURCH RD CAMP HILL, PA 17011 RE: 78112 NEIL J. WAGER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : NEIL I WAGER 220 WOOD STREET, CAMP HILL, PA 17011 Social Security A 601-16-7981 Date of Birth: 07-15-1969 SU10-381790 78112-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: NEIL WAGER -VS- LI, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 00-5007 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. 2ULLI, 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: 07/15(2002 BRIAN N. 2ULLI, ESQ. Attorney for DEFENDANT DE11-345248 783--L2--I,03 COMMONWEALTH 0 7 P ENN S YLVAN ZA COUNTY O V CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS NEIL WAGER -VS- LI. ET AL RICNAED J. PATTERSON RICHARD PATTERSON SANS. L. JONES, N.D. MWM H. EATON, N.D. MEDICAL RECORDS MEDIC r. RECORDS NEDICAL RECORDS MEDICAL RECORDS TERM, CASE NO: 00-5007 TO: PATRICK CECILE, ESQ (COD) NCS on behalf of BRIAN N. ZOLLI. ESQ. intends to serve a subpoeom 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 ands, than the subpoena may be served. Complete copies of any reproduced records my be ordered at your expense by completing the attached counsel card and returning same to NCS or by contacting our local NCS office. DATE: 0612412002 CC: BRIAN V. z0=, ESQ. - 00-324 Any questions regarding this matter. contact WS on behalf of BRIAN N. SDLLI, ESQ. Attorney for DE$EMOANT THE NCS cow INC. 1601 MARKET STBEET #800 PHILADELPHIA, PA 19105 (215) 246-0900 DE02-190848 7 8 1 1 2- C 0 1 NEIL WAGER COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VS LI File No. 00-5007 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: RICHARD PATTERSON (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 ST., #800, PHILA., 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: BRIAN N. ZULLI z ES ADDRESS: 2411 NORTH FRONT ST. HARRISBURG PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR DEFENDANT -BY IE COURT: DATE: / F _Prothonotsry/Clerk. lviaion _- De ty Seal of the Court /'P;; 7,071 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RICHARD PATTERSON 4601 DEVONSHIRE ROAD HARRISBURG, PA 17110 RE: 78112 NEIL J. WAGER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : NEU, J. WAGER 220 WOOD STREET, CAMP HELL, PA 17011 Social Security A 601-16-7981 Date of Birth: 07-15-1969 SU10-381792 7 8 1 1 2- 1, 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: NEIL WAGER -vS- LI, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 00-5007 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, 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: 07/15/2002 BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT DE11-345249 7 8 1 1 2- 1,0 4 COMMONWEALTH 07 P ENN S YI?VAN IA COUNTY O V CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS NEIL WAGER -VS- LI, ET AL RICHARD J. PATTERSON RICHARD PATTERSON SAMORL L. JONES. N.D. Even H. EATON, N.D. MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TERM, CASE NO: 00-5007 TO: PATRICK 6ECII.E, ESQ (COD) MCS on behalf of BRIM N. EHLLh ESO. intends to serve a subpoena identical to the one that is attached to this notice. Too 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 any be served. Complete copies of any reproduced records way be ordered at your expense by completing the attached counsel card and returning same to NCS or by contacting our local NCS office. DATE: 0612412002 CC: RBIAN W. Rm.LI. ESQ. - 00-324 Any questions regarding this matter, contact NCS on behalf of RRIAN N. ZW.LI, ?• Attorney for ?PElDANT THE NCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-190848 7 0 X X2 - C O 1 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NEIL WAGER LI File No. 00-5007 TO: CUSTODIAN OF RECORDS FOR: SAMUEL JONES (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 ST., #800, PHILA., 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: BRIAN N. ZULLI, ESQ. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TELEPHONE: 215446-0900 SUPREME COURT ID#: ATTORNEY FOR DEFENDANT BY HE C URT: _ DATE: y 1 .20C,E-S Prothonotary/ClerlriEM1! PDivision D ty Seal of the Court „Y. !'Fff 71479 "- VS EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SAMUEL L. JONES, M.D. 165 SOUTH 32ND STREET CAMP HILL, PA 17011 RE: 78112 NEIL J. WAGER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and Including the present. Subject : NEIL J. WAGER 220 WOOD STREET, CAMP HIT J, PA 17011 Social. Security A 601-16-7981 Date of Birth: 07-15-1969 SU10-381794 78112-T GQ-4. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS NEIL WAGER TERM, -VS- CASE NO: 00-5007 LI, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, 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: 07115/2002 BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT DE11-345250 '783__L2_-I,0!5 IN THE MATTER OF: NEIL WAGER -VS- LI, ET AL RICHARD J. PATTElSOR RICRARD PATTCASOR SANDI L L. JONES. N.D. EDIiM R. RATOR, M.D. T0: PATRICK 6ECE).E. ESQ (COD) MEDICAL RECORDS !®IM RECORDS 1/ICAL RECORDS MEDICAL RECORDS COURT OF COMMON PLEAS TERM, CASE NO: 00-5007 ICS on behalf of BRIAN R. ZOi.L2. ESO. Intends to serve a subpoena, identical to the ons that is attaahsd to this notice.. Too be" twsat7 (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 am%, then the subpoena way be served. Complete copies of any reproduced records nay be ordered at your espease by completing the attached counsel card and returning same to WS or by contacting our local MCS office. DATE: 0612412002 ICS on behalf of BRIAH R. 2DLLI, EB0. Attorney for DElAI m cc: BRIM i.; mm. ESQ. - 00-324 Any questions regarding this matter, contact TIM WS GROUP INC. 1601 MARKET 4 lim6T f800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-190848 7 8 1 3.2 - 0 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NEIL WAGER VS LI File No. 00-5007 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: EDWARD H. EATON, M.D. tName 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 ST., #800, PHILA., 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: BRIAN N. ZULLI, ESQ. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TELEPHONE.. 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: -, 1 A,F- 1 21-MA_ Seal of the Court /C:F 7 /07_ _ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EDWARD H. EATON, M.D. 1430 BRIDGE STREET NEW CUMBERLAND, PA 17070 RE: 78112 NEIL J. WAGER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : NEIL J. WAGER 220 WOOD STREET, CAMP HILL, PA 17011 Social Security AF 601-16-7981 Date of Birth: 07-15-1969 SU10-381796 78112-1L.05 C7 c? T?j, .-i y? r> gy=p = - =, r NEIL WAGER, Plaintiff V. BIN S. LI, and ZHENG WEI BAI, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-5007 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter settled, satisfied and the docket discontinued. Date: Respectfully submitted, MYCHAK, GECKLE & WELKER, P.C. By: (f_ ?-° Patrick G. Geckle, Esquire Attorney I.D. No. 26718 230 South Front Street, 11th Floor Philadelphia, PA 19102 (215) 735-3326 lp- 7C. cc ;??;