HomeMy WebLinkAbout07-10-09IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
TY AARON BERRIOS
Vs.
HOLY SPIRIT HOSPITAL ; No. ~~ ~ "S ~ ~ ~
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NOTICE OF FILING MOTION FOR SANCTIONS
TO: Holy Spirit Hospital & Health System, 503 N 21st St. Camp Hill, PA 17011
TAKE NOTICE that the within Motion will be presented on July 10, 2009 before the
Motions Judge at the date above-noted.
TY AARON BERRIOS
52 WINDSOR WAY
CAMP HILL, PA 17011
717-574-1948
PRO SE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
TY AARON BERRIOS
Vs.
HOLY SPIRIT HOSPITAL
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No. ~~~- rJScSt~
MOTION TO COMPEL DISCOVERY AND FOR SANCTIONS
Plaintiff, pro se, moves pursuant to Pa.R.C.P. 4019(a)(1)(vii) to compel Defendant Holy
Spirit Hospital to produce documents, and advances the following in support thereof.
I. On or about ,Plaintiff served subpoena upon these Defendant.
2. Defendants have acknowledged that they have possession of these documents, but have
refused to produce them.
6. The documents are discoverable because they may establish that, the plaintiffs wife is
mentally incompetent and not able to file a divorce complaint.
WHEREFORE, Plaintiff requests the Court to enter an Order compelling Defendant HOLY
SPIRIT HOSPITAL to produce the documents requested on exhibit A for one LUCINDA K.
BERRIOS. Plaintiff further requests an award of reasonable expenses pursuant to Rule
4019(a)(1) and (c).
By
TY AARON BERRIOS, PRO SE
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Exhibit A
The entire chart of the patient referred to, including but not limited to, the following
specific categories of writings:
New Patient Application
Health Questionnaire
Medical History
Findings on Physical Examination
Progress Notes
Chart Entries
Reports of diagnostic imaging reports, including X-ray, MRI, CT Scan
Reports of Other Clinical Testing Procedures
Results of Laboratory Tests
Pathology Reports
Impressions
Diagnoses
Treatment
Prescriptions for drugs
Prognoses
Reports re Hospitalization
Emergency Room Visits
Admissions
Reports of history and physical exam
Operations
Consultations
Discharge Summaries
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Informed Consent Forms
Medical-Legal Reports
Photographs
Video tapes of operations such as arthroscopy
Correspondence
Notes
Memoranda
Disability Forms
Work/School Absence/Excuse Forms
Lien forms
Billing/Payment Records
Insurance forms
Authorizations for release of records
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IN THE COURT OF COMMON PLEAS OF E COUNTY
PENNSYLVANIA
TY A. BERRIOS
vs.
HOLY SPIRIT HOSPITAL
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No. ~pq - SSSa
CERTIFICATE OF SERVICE
I TY AARON BERRIS
certify that on JULY 10, 2009
MOTION TO COMPEL DISCOVERY
Holy Spirit Hospital & Health System
503 NORTH 21 TH ST
CAMP HILL, PA 17011
the undersigned, hereby
a true and correct copy of the
was served on the following:
BY: TY A. BERRIOS
(NAME)
52 WINDSOR WAY
(STREET ADDRESS)
(STREET ADDRESS)
CAMP H I L L, PA 17011
(CITY/TOWN, STATE, ZIP CODE)
717-574-1948
(PHONE NUMBER)
SIGNATURE:
DATE: