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HomeMy WebLinkAbout01-0137NANCY A. SWEATLOCK, Plaintiff ERIK N. REES, Defendant 302 Monroe Street Mechanicsburg, Pa. 17055 IN THE COURT OF COMMON PLEAS CUMBERLJ~ND COUNTY, PENNSYLVANIA CIVIL ACTION - I~W JURY TRIAL DEMANDED WRIT OF SZB~4ONS You are notified that NANCY A. SWEATLOCK, Plaintiff, has commenced an action in CIVIL ACTION LAW - JURY TRIAL DEMANDED against you which you are required to defend. DATED PROTHONOTARY NANCY A. SWEATLOCK, Plaintiff ERIK N. REES, Defendant IN THE COURT OF COMMON PLEAS CUMBERL~ND COUNTY, PENNSYLVANIA NO. 0/- /37 ~ : : CIVIL ACTION - : : JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons in the above-captioned matter. Please have the Sheriff serve the Defendant at the following address: ERIK N. REES 302 MONROE STREET MECHA/qICSBURG, PA 17055 Thank you. Dated 17~orth Front Street Harrisburg, PA 17102 {717)234-4178 Attorney for Plaintiff ~d ~ Z Z Z ~0 SHERIFF'S RETURN - CASE NO: 2001-00137 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERL~/qD SWEATLOCK NANCY A VS REES ERIK N REGULAR CPL. TIMOTHY REITZ , Cumberland County, Pennsylvania, says, the within WRIT OF SUMMONS REES ERIK N DEFENDANT , at 0020:08 HOURS, at 856 BOILING SPRINGS RD MECHA/~ICSBURG, PA 17055 ERIK REES a Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 31st day of January , 2001 true and attested copy of WRIT OF SUMMONS by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.58 Affidavit .00 Surcharge 10.00 .00 33.58 Sworn and Subscribed to before me this ~9~- day of R. Thomas Kline 02/01/2001 PURCELL, KRUG & HALLER epury erlr~, THOMAS, THOMAS & HAFER, LLP Jeffrey B. Rettig, Esquire Identification Number: 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW Attorneys for Defendant NANCY a. SWEATLOCK, Plaintiff V. ERIK N. REES, Defendant CIVIL ACTION - LAW NO. 137 CIVIL TERM JURY TRIAL DEMANDED TO THE PROTHONOTARY: PRAECIPE Please enter the appearance of Jeffrey B. Rettig, Esquire of Thomas, Thomas & Hafer, LLP on behalf of Erik N. Rees, Defendant in the above captioned matter. :125217.1 Respectfully submitted, THOMAS, THOMAS & HAFER, LLP CERTIFICATE OF SERVICE l, JEFFREY B. RET-rIG, ESQUIRE, hereby certify that I have served a true and correct copy of the foregoing docum.~ent on the follow?~q person by placing same in the United States mail, postage prepaid, on the ~ day of ./[/~..~t./( ,2001. Howard B. Krug, Esquire Purcell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 iER, LLP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SWEATLOCK VS. : REES : NO. 01 137 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days the subpoena(s) is sought to be A copy of the Notice of Intent, subpoena(s) is attached to this No objection to the subpoena(s) has been received, The subpoena(s) which will be served is identical the subpoena(s) which is to Serve the Subpoena(s). prior to the date on which served, including the proposed certificate, and to attached to the Notice of Intent Date: 4/17/01 File #: M273240 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 717-255-7237 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 INC. By: Christine Janiszewski IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SWEATLOCK Vs. REES No. 01 137 TO: HOWARD KRUG, ESQ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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. Date: /26/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LAi~DIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 ATTOP_NEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 INC. By: Christine Janiszewski Enc (s) File Copy of subpoena(s) Counsel return card M273240 SWEATLOCK Vs. REES G0~t~DNWEALTHOF p~%LqYLVANIA OOUNTYOFCZ~WRIA~D : Fi]eNo. 01 137 SUBPOENA TO PROOUCE D(X~NTS OR' TH I NGS ~FOR DISOOVER¥ PURSUANT TO RULE 4009.22 TO: ORTHO SURGEONS OF CENT PA, 99 NOVEMBER DR, CAMP HILL PA 17011 (Na~e of Person ow- Entity) Within twenty (20) days after semvice of this sub~ns, you a~e o~dered by the court to ADDENDUM prc~duce the following do~t.~ o~l~in~s~]) You may deliver or mail legible copies of the ~ts o~ produce things requested bt this subpoena, together with the certificate 6f ~liance; to the party making this request at the address listed above. You have the right to seek in advance the reasonabl~ cost of preperin9 the copies or producin9 the things sought. If you fail to produce the doct~nents o~ things re~ired by this subl~ena within twenty (20) days after its service, the party I serv,!~ thin s~ena may seek a court orde~- c~',~elling you to cu,~ly with it. ' ' "~ ~ ' THIS SUBP~NA WAS ISS~O AT THE REQUEST Of= 11~ F(~LO~IN~ PERSON: NAME: JEFFREY B RETTIG, ESQ ADORESS: ATTN: cArOL LANDIS ~ hARRISBURG, ~ 17108 TELFpI-K~E: SUPREME COURT ID # 215-~35-3212 ATTORNEY FOR: 19616 DEFENDANT M273240-01 OATE: - ~/~/~/ Sea! o~the Court 8Y Tt~ I~h~)o, teryJOl~rk', CiVi 1' Divisio~ D~outy (Eff. 7'/97) SWEATLOCK Vs. REES ADDENDUM TO SUBPOENA No. 01 137 CUSTODIAiq OF RECORDS FOR: ORTHO SURGEONS OF CENT PA 32~Y AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA~, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: NANCY A SWEATLOCK ADDRESS: 1013 MEADOWVILLE CT HARRISBURG PA CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273240~01 Authorized signature for ORTHO SURGEONS OF CENT PA *** SIGN AND RETURN THIS PAGE *** sw .AT dc i~V~ .' REES 01 137 ~ SUBPOENA TO PRCOUC~ IXX3JMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR WILLIAM APOLLO, 1000 N FRONT ST, WORMLEYSBURG PA 17043 (Name of Person cc Entity) Within twenty (20) days afte~ service of this subpoena, you are o~dered by the court to produce the following docu~ent.~ cc things: .... ! ,SEE Al IACHED at ADDENDUM I~EDICA~ LEGAL REPRODUCTIONS~A.TJ~a~;~Ss)~940 DISSTON ST., PHILA., PA You may de]ive~ or mail legible copies Of the ~ts oc pC0duce things requested this. S6bpoena, tc~jether w~tn, the certificate 6f~ '~liance, -to the party making t. hi~ request et the address listed above. You have the right to seek in advance the rea~,onabt~ cost of preparing the copies or producing the things sought; (20) compel ]ing you to co,~ly THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NA~: JEFFP~EY B RETTIG, ESQ ADORESS: {~T~N: CAROL LANDIS TELF?HONE ~ ,, ', SUPREP~ COURT ID ~t 215-335-3212 A3'rORNFy FOR: 1961(5 DEFENDANT BY THE COURT: If you fail to produce the doctxnents cc things r;eqUired by this subpoena within t~enty days altec its service, the pa~ty serving -thi.~ subpoena may seek a court ocde,- (£ff. SWEATLOCK Vs. REES ADDENDUM TO SUBPOENA No. 01 137 CUSTODID~N OF RECORDS FOR: DR WILLIAM APOLLO ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: NANCY A SWEATLOCK ADDRESS: 1013 MEADOWVILLE CT HARRISBURG PA CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above m~ntioned have been produced. NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the followin9 documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed te UMBERLAND 273240-02 Authorized signature for DR WILLIAM APOLLO *** SIGN AND RETURN THIS PAGE *** SWEATLOCK REES 01 137 TO: SUSF~D~NA TO PROEXJO~ DOZtI~ENTS O~ THIN~S FO~ DISOOVERY PURSUANT TO RULE 4009.22 DR DAVID FERNER, '4301 LONDONDERRY RD, HARRISBURG PA 17109 (Name of Pe~sc~ ~ Entity) Within,twenty (20) days af:ter semvice of this SU~poen9, you are= omde~e.d~ by the court to D ADDENDUM - Yo~ may deliver or mail legible copies 6f the ~ts 0~ p~oduce things requested this subpoena, togethe~ with the certificate of~ ~liance, tothe pa~ty making thi[ request at the address listed above. You have the might to seek in advance the reasonabl~ cost of preparing the copies or producing the things sought. If you fail to produce the doctm~ents oc things required by this subpoena within twenty days after its ,Se~v, lce~ the pa~t¥ set. ring thi-~ s~ub~a may seek a court orde,- (2O) o.x,~elling you to cc~ly with:'it. THIS SU~:K)ENA WAS ISSUED AT THE REQUEST Of: THE FOLLOWING PERSON: 'JEFFREY B RETTIG, ESQ AT~N- ~ARoT, T.~NDIS I-LARRISBURG, PA 17108 ~' [ v?:;'~ ~ !{'~: ~' "' 215 ~'335-3212 19616 , DEFENDANT ELEPH0~E: , , UPRISME CC~IRT ID fi: I'TORNEY FOR: ;240-03 BY THE OOURT: Seal 6f the Court' Deputy (Elf, ~/9i' ) ADDENDUM TO SUBPOENA SWEATLOCK Vs. REES No. 01 137 CUSTODIAN OF RECORDS FOR: DR DAVID FERNER ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMOP3%NDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: NANCY A SWEATLOCK ADDRESS: 1013 MEADOWVILLE CT ~ua_RRISBURG PA CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-rAYS ( ) RECORDS / XRAYS have been destroyed te 3MBERLAND !7324O-03 Authorized signature for DR DAVID FERNER *** SIGN AND RETURN THIS PAGE *** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY S~EATLOCK Vs. REES NO. 137 CV 2001 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3.No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 02/07/02 File #: M282854 JEFFREY B RETTIG, ESQUIRE 305 N FRONT ST 6TH FL PO BOX 999 HARRISBURG, PA 17108 717-237-7101 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) INC, By: Christine Janiszewski IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY S~EATLOCK ' VS. REES NO. 137 CV 2001 TO: HOWARD KRUG NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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. Date: 01/17/02 Enc (s): File #: Copy of subpoena(s) Counsel return card M282854 JEFFREY B RETTIG, ESQUIRE 305 N FRONT ST 6TH FL PO BOX 999 HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 INC. By: Christine Janiszewski CO--TH OF p/~4NSYLVANIA ~0UNTY OF Om4BERLAND SWEATLOCK : VS. : File No. REES : 137 CV 2001 SUbPOeNA TO PRCOUC DOCU' NTS BILLIN~ REQUESTED TO: DR NATHAN HERD, 2704 MARKET ST, CAMP HILL PA 17011 (Name of Pe~son o~ Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docu~ent.~ or things: SEE A'rTACI41 D ADDENDUM at MEDICAL LEQAL RE~RODUCTION~,Ad~ss~940 DISSTON ST., PHILA., PA You may deliver or mai] legible copies of the docc~nents or produce things requested this subpoena, together with the certificate of co,~liance, to the party making thiz request at the address listed 'above. You have the right to seek in advance the rea¢onabl~ cost of preparing the copies or producing the things sought. IF you fail to produce the doctrnents or things required by this subpoena within twenty (20) days after its service, the party serving 'this subpoena may seek a court orde,~ =a~elling you to comply with it. TH I$SL~POENAWAS I SSU~D ATT HE REQUEST OF THE FOLLOWIN<]PERSON: NAME: JEFFREY B RETTIG, ESQ 305 N FRONT ST 6TH FL TELEPHONE: SUPREME ~T ID # A~-rC~NEY FC~9: HARRISBURG, PA 17108 215-335-3212 DEFENDANT M282854-01 o / z/o2 DATE: '~eal of the ~z~Jrt BY THE COURT: ProthonOtary~16rk, Civi I ~Visi~ ~uty (Elf. 7/97) ADDENDUM TO SUBPOENA SWEATLOCK Vs. REES No. 137 CV 2001 CUSTODIAN OF RECORDS FOR: DR NATHAN HERD **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: NANCY A SWEATLOCK ADDRESS: DATE 0F BIRTH: 08/09/38 SSAN: 210283635 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN ] R3ECOF~gS AREATTACHEDHER3ETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-P~AYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M282854-01 Authorized signature for DR NATHAN HERD *** SIGN AND RETURN THIS PAGE *** MEDICAL LEGAL REPRODUCTIONS. INC. Main Office Phone: (215) 335-3212 Jefferson Bldg., Suite 926 4940 Disston Street Fax: (215) 338-2980 1015 Chestnut Street Philadelphia, Pa. 19135 E-mail Address: legal@medleg.com Philadelphia, Pa. 19107 ADDENDU~ COMPLETE COPES OF ANY AND ALL RECORDS IN MEDICAL FILE, INCLUDING BUT NOT LIMITED TO, ANY AND ALL RECORDS, CORRESPONDENCE, FILES AND MEMORANDUMS, PROGRESS NOTES, CLINIC NOTES, INPATIENT AND/OR OUTPATIENT RECORDS, RADIOLOGICAL REPORTS, HANDWRITTEN NOTES, BILLING AND PAYMENT RECORDS RELATING TO ANY EXAMINATION, INPATIENT AND/OR OUTPATIENT CONSULTATION, ETC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NANCY A. SWEATLOCK, Plaintiff ERIK N. REES, Defendant CIVIL ACTION - LAW NO. 137 CIVIL TERM JURY TRIAL DEMANDED WITHDRAWAL OF APPEARANCE Kindly withdraw the appearance of Jeffrey B. Rettig, Esquire and Thomas, Thomas & Hafer, LLP, as attorney for Defendant in this matter. ,J~'ffrey B. Rettig, Esquire {~05 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7639 ENTRY OF APPEARANCE Kindly enter the appearance of Jeffrey B. Rettig, Esquire and Hartman, Osborne & Rettig, P.C., as attorney for Defendant in this matter. By: HAI~TMAN, OSBORNE & RETTIG, P.C. J,e~frey B. ettig, Esquire //26-128 Walnut Street Harrisburg, PA 17101 (717) 232-3046 CERTIFICATE OF SERVICE I do hereby certify that I sent a true and correct copy of the foregoing document to all counsel of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Howard B. Krug, Esquire Pumell, Krug & Hailer 1719 North Front Street Harrisburg, PA 17102 Date: By: THOMAS, THOMAS & HAFER, LLP NANCY A. SWEATLOCK, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND CO., PENNSYLVANIA : OI ~ v. : No. 137 Civil Term ERIK N. REES, : Defendant : JURY TRIAL DEMANDED pI~CIPE To the Prothonotary: Please mark the above-captioned matter settled, and discontinued. satisfied Date: PURCELL, KRUG & HALLER, 171~North F~ont Street Harrisburg, PA 17102 ID No. 16826 (717)234-4178 Attorney for Plaintiff