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