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Home My WebLink About10-0398CARROL PLETCHER, 103 June Drive Camp Hill, PA 17011, Plaintiff V. THE TJX COMPANIES, INC., a/k/a MARSHALLS, 6520 Carlisle Pike Mechanicsburg, PA 17050-5240, Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Issue summons in the above case. N O d W N CM mFr n ?rn Writ of Summons shall be issued and forwarded to the Sheriff of Cumberland County for service on the Defendant at the following address: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Case No. Civil Action n C Y f :.I t? 'c THE TJX COMPANIES, INC., a/k/a MARSHALLS 6520 Carlisle Pike Mechanicsburg, PA 17050-5240 Date: 1_ako By: WRIT OF SUMMONS CUNNINGHAM & CHERNICOFF, P.C. Wad-D. Anningham, Esquire A Supreme Court I.D. No. 23144 P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: 717-238-6570 To: THE TJX COMPANIES, INC. a/k/a MARSHALLS, 6520 Carlisle Pike, Mechanicsburg, PA 17050-5240 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. psi "440( 0- 4:64e& Prothonotary/Clerk, Civil Division Date: eputy 9ZOP - C4 a3G373 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson IL E` Sheriff Tr r ?:`,„Y ??+ptr Ct iii+nt?rr?r ? , Jody S Smith 20 10 JA IN 2 1 Chief Deputy Edward L Schorpp t?? ?. Solicitor Carrol Pletcher Case Number vs. 2010-398 The TJX Companies, Inc. a/k/a Marshalls SHERIFF'S RETURN OF SERVICE 01/19/2010 05:01 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2010 at 1701 hours, she served a true copy of the within Writ of Summons, upon the within named defendant, to wit: The TJX Companies, Inc. a/k/a Marshalls, by making known unto Sheryl Bharat, Store Manager at 6520 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.44 January 20, 2010 So ANSWERS, Y R ANDERSON, SHERIFF By ,'rd ok" Deputy Sheriff !c Goun`,Suite S1eit Teiensofi inc BONNER KIERNAN TREBACH & CROCIATA, LLP !My BY: MARK A. LOCKETT, ESQUIRE / KATHERINE J. SULLIV2tN,F IDENTIFICATION NO: 50023 / 206517 12= 5 L EIGHT PENN CENTER, SUITE 200 C?,Pti 1628 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEYS FOR DEFENDANTS, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls) CARROL PLETCHER COURT OF COMMON PLEAS CUMBERLAND COUNTY V. THE TJX COMPANIES, INC. a/k/a MARSHALLS Plaintiff Defendants NO: 10-398 CIVIL ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance in the above-entitled action on behalf of defendants, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls). BONNER KIERNAN TREBACH & CROCIATA, LLP BY: MARK A. LOCKETT(,-V-SQUIRE KATHERINE J. SULLIVAN, ESQUIRE Attorneys for Defendants, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc.) BONNER KIERNAN TREBACH & CROCIATA LLP BY: Mark A. Lockett, Esquire/ Katherine J. Sullivan, Esquire- IDENTIFICATION NO: 50023 / 206517 1628 JOHN F. KENNEDY BOULEVARD 2 10 FEB 22 ' ` ? EIGHT PENN CENTER, SUITE 200 PHILADELPHIA, PA 19103 (215) 569-4433` ATTORNEYS FOR DEFENDANTS, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls) CARROL PLETCHER Plaintiff V. THE TJX COMPANIES, INC. a/k/a MARSHALLS Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-398 CIVIL PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a Rule upon Plaintiff to file a Complaint within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. BONNER KIERNAN TREBACH & CROCIATA, LLP B 4I4 R I ?L? _4e<A I J A1/ 1 A MARK A. LOCKETT,`I?SQUIRE KATHERINE J. SULLIVAN, ESQUIRE Attorneys for Defendants, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls) RULE TO FILE COMPLAINT AND NOW, this.22'fc&y of?, 2010, a Rule is hereby granted upon Plaintiff to file a Complaint herein within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. PROTHONOTARY CARROL PLETCHER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 10-398 CIVIL THE TJX COMPANIES, INC. ° C.; a/k/a MARSHALLS, Defendants NOTICE t; -' YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims-het forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if 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 for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 Jordan D. Cunningham, Esquire Cunningham & Chernicoff, P.C. P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: 717-238-6570 Facsimile: 717-238-4809 Email: jcunninghamgcclawpc.com CARROL PLETCHER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO. 10-398 CIVIL THE TJX COMPANIES, INC. a/k/a MARSHALLS, Defendant COMPLAINT AND NOW comes the Plaintiff, Carrol Pletcher, by and through her counsel, Cunningham & Chernicoff, P.C., who files this action at law and in support thereof, makes the following averments: 1. Plaintiff, Carrol Pletcher, is an adult individual who resides at 103 June Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant, The TJX Companies, Inc. a/k/a Marshalls, is a corporation registered to do business in the Commonwealth of Pennsylvania, operates a retail store which specializes in the sale of home furnishings and accent pieces and who operates, trades, and does business as Marshalls at 6520 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania. 3. At all times relevant hereto, Defendant was in exclusive possession, management, and control of the store, individually and through its employees who were acting within the course and scope of their employment by the Defendant and in furtherance of Defendant's business. 4. On or about January 21, 2008, Plaintiff was a business invitee/visitor to the store, had shopped in the store, had chosen articles to purchase, had checked out at the register, and was leaving the store, at which time she noticed a display of sundry items including pillows, the material of which appeared to match a coverlet which she had purchased. The display of chairs, a table, and other products were placed on a movable platform, the base of which platform was approximately three (3) to five (5) inches from the floor and mounted on wheels or castors so that the platform could be moved from place to place throughout the store. 6. Plaintiff, upon seeing the display, approached the display which display was located in a general area of the store near the front door, to match the color of the coverlet which she had purchased against the color of the material of the pillow located on the display. 7. Plaintiff approached the display and when she reached for the pillow, her handbag or shopping bag became entangled with a wire bin in which other products were being stored and displayed which bin was located along the side of the display. 8. Plaintiff's movement to reach for the pillow was interrupted and she turned to untangle her handbag and shopping bag from the wire mesh bin and, as she did so, her foot became caught underneath the raised platform causing her to lose her balance. In an effort to prevent herself from falling, Plaintiff attempted to steady herself on the chairs of the display, but as she did so, the display began to move as the castors on which the platform was sitting were not locked. 2 9. As a result of the display moving, items on the display began to fall from the display causing the Plaintiff to react, and in reacting, the Plaintiff's foot became caught under the platform, causing her to slip, stumble, and fall, hitting her head on both the platform and the floor, resulting in serious and permanent injuries as set forth below. 10. The display's collapsing and moving and Plaintiff's resulting fall caused Plaintiff, Carroll Pletcher, to sustain injuries and damages as the direct result of the negligent, careless, and reckless manner in which Defendant and Defendant's agents placed, designed, and constructed the display as follows: a. Defendant and its agents caused or permitted a display of its goods to be constructed in such a manner as to collapse upon a business invitee taking items from the display, causing an unreasonable risk of injury to the Plaintiff and to other business visitors; b. Defendant: and its agents caused or permitted a display of its goods to be placed upon a mobile platform without the castors or wheels of the platform being placed into a locked position and as a result of Defendant and its agents failure to secure the castors and wheels . Plaintiff, a business invitee, approached the display and upon reaching out to remove items from the display, the display moved to such an extent and to such a point that it posed an unreasonable risk of injury to Plaintiff and other business invitees; C. Defendant and its agents caused or permitted a display of its goods to be placed upon a mobile platform, which platform was designed and built in a manner that the clearance between the bottom of the platform and the floor was of such a height that Plaintiff and other business invitees, to unknowingly and without warning, could place their feet beneath the platform, representing a tripping hazard, thus placing Plaintiff and business invitees at risk, all of which posed an unreasonable risk of injury to Plaintiff and other business invitees. d. Defendant and its agents caused or permitted the goods and items displayed on the platform to be placed at such a height and at such a location that Plaintiff or any other business invitee who attempted to remove items from the display by reaching over the vertical plane of the side of the platform had to place their feet under the raised portion of the platform, thus placing the Plaintiff and other business invitees at risk of tripping, losing their balance and/or, when attempting to steady themselves upon the display as a result of tripping or losing their balance, to discover that the castors and wheels of the platform upon which the display was built were not locked in a secure position, allowing the entire display to move, all of which posed an unreasonable risk of injury to the Plaintiff and other business invitees; 4 Defendant and its agents failed to make a reasonable inspection of the display which would have revealed the existence of a dangerous condition posed by riot only the height of the space and manner in which goods were set forth on the display but also the height between the floor and the bottom of the platform which allowed it to be accessed by Plaintiff's and other business invitees' feet but also by the fact that the castors or wheels of the platform on which the display had been built had not been locked in a secure position, all of which posed an unreasonable risk of injury to the Plaintiff and other business invitees; f. Defendant and its agents caused or permitted the goods and items to be placed on the display, failed to take special precautions against the collapsing of the goods on the display, failed to erect a barrier around the bottom of the platform and the floor; failed to lock the castors or wheels of the platform on which the display was constructed in order to protect the Plaintiff and business invitees who would be taking items from the display; g. Defendant and its agents caused or permitted a display of its goods to be placed in wire mesh baskets in such close proximity to a larger display built on a movable platform that the baskets represented a danger in becoming entangled with Plaintiff's and other business invitees' shopping 5 bags and purses thus placing Plaintiff and other business invitees at risk, all of which posed an unreasonable risk of injury to Plaintiff and other business invitees; h. Defendant and its agents failed or permitted the failure to warn the Plaintiff and other business invitees of the danger that the display represented due to the manner in which it was designed or constructed, the height to which it was constructed, and the failure to lock the castors or wheels to stabilize the platform upon which the display when items were taken from it by Plaintiff and/or business invitees; i. Defendant and its agents failed to give warning of the dangerous condition posed by the design and construction of the display and the unstable platform on which the display had been built and failed to take any safety precautions to prevent injury to the Plaintiff and other business invitees; Defendant and its agents allowed the display to remain in a dangerous and unsafe condition after notice or opportunity for notice of its dangerous propensities should have been observed; k. Defendant and its agents failed to properly maintain the display so that it would not represent a danger to the Plaintiff or other business invitees and properly display goods for sale; 1. Defendant and its agents failed to warn the Plaintiff and other business invitees of the likely malfunction of the display; 6 M. Defendant and its agents failed to warn the Plaintiff of the likelihood that the display would move, it could cause the Plaintiff to trip, and/or had the potential to collapse; n. Defendant and its agents failed to insure that the display and the platform on which it sat operated in a safe and proper manner; o. Defendant and its agents failed to make repairs which were necessary and proper in order to assure that the display and the goods contained on the display would not collapse upon the Plaintiff or any other business invitee; and p. Defendant and its agents failed in providing adequate safe guards to prevent the injury to the Plaintiff and other business invitees. 11. As a direct result of the Defendant's, and its agents', negligence, carelessness, and recklessness, Plaintiff fell, sustained painful and permanent injuries to her head, neck, body, buttocks, arms, and legs, both internally and externally; a severe shock to her nerves and nervous system; injury to her lower back; and other severe and painful injuries, including but not limited to bruising of her arms, legs, a concussion, sprained left wrist, sharp pain in her neck, pain in her mid-back, headaches, nausea, and pain parethesias into the left upper extremity and arm and to her head; all of which injuries have caused Plaintiff great pain and suffering and may continue for an indefinite time in the future. 7 12. By reason of the aforesaid injuries sustained by Plaintiff, Carroll Pletcher, she was forced to incur liability for medical treatment, medicine, hospitalization, and similar miscellaneous expenses in and about an effort to restore herself to health; and because of the nature of such injuries, she is advised and therefore avers that she will be forced to incur similar expenses in the future. 13. As a result of said injuries, Plaintiff had undergone and in the future will undergo great mental and physical pain and suffering, great inconvenience in carrying out her daily activities, and loss of life's pleasures and enjoyment; and claim is made therefore. 14. As a result of said injuries, Plaintiff by reason of not being able to fulfill her employment duties has sustained a loss of earnings for the period between January 21, 2008 and February 8, 2008. 15. As a result of said injuries, Plaintiff has sustained a permanent impairment of earning power and earning capacity and claim is made therefore. 16. Solely as the result of Defendant's and its agents' negligence, carelessness, and recklessness, Plaintiff has and will in the future be unable to attend to her usual and daily duties and employment, to her financial detriment and loss. WHEREFORE, Plaintiff demands judgment in favor of the Plaintiff and against the Defendant in an amount in excess of $10,000 together with costs and interests. CUNNINGHAM & CHERNICOFF, P.C. Date: By: J d unningham, Esquire PA Supreme Court I.D. No. 23144 P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: 717-238-6570 F:\Home\AHEWITT\DOCS\O-P\PLETCHER, CARROL\complaint 031010.wpd 9 VERIFICATION The undersigned verifies that the statements contained in the foregoing are true and correct to the best of my knowledge, information and belief. 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: -3 , ze arrol Pletcher CERTIFICATE OF SERVICE I do hereby state that on the day of March 2010, I served a true and correct copy of the foregoing in the above captioned matter, by placing the same in the United States mail, first- class, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Mark A. Lockett, Esquire Katherine J. Sullivan, Esquire Bonner, Kiernan, Trebach & Crociata, LLP Eight Penn Center, Suite 200 1628 John F. Kennedy Boulevard Philadelphia, PA 19103 Legal Assistant BONNER KIERNAN TREBACH & CROCIATA, LLP BY: JENNIFER A. MCGARRITY, ESQUIRE IDENTIFICATION NO: 93037 EIGHT PENN CENTER, SUITE 200 1628 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEY FOR DEFENDANTS, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls) COURT OF COMMON PLEAS CARROL PLETCHER CUMBERLAND COUNTY Plaintiff ~ a v. THE TJX COMPANIES, INC. a/k/a ~ ~.~ -~v ~~ MARSHALLS ~ ~ n Defendants NO: 10-398 CNIL ..~ ~` ~' WITHDRAWAL OF APPEARANCE ~~ ~~ ~ ~ ~ TO THE PROTHONOTARY: car, Kindly withdraw my appearance in the above-entitled action on behalf of defendants, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/Wa Marshalls). TO THE PROTHONOTARY: BONNER KIERNAN TREBACH & CROCIATA, LLP KATHERINE J. SULLIY'AN #206517 Attorney for Marmaxx Operating Corp.( improperly designated as The TJX Companies, Inc.) ENTRY OF APPEARANCE Kindly enter my appearance in the above-entitled action on behalf of defendants, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/Wa Marshalls). BONNER KIERNAN TREBACH & CROCIATA, LLP BY: / ~ _~ JENNIFER A. McGARRITY, ESQUIRE Attorney for Marmaxx Operating Corp.( improperly designated as The TJX Companies, Inc.) 12121001 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER PLAINTIFF/S VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS DEFENDANT/S COURT OF COMMON PLEAS NO. 10-398 CIVIL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 C') G p "?+ --4 rn r - Co c- n -n rri ZO cl) •.- 0 rr, -4 r r-n 7a AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 1/10/12 MARK A. LOCKETT, ESQ. ATTORNEY FOR DEFENDANT 0960.126 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER PLAINTIFF/S COURT OF COMMON PLEAS VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS NO. 10-398 CIVIL DEFENDANT/S NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JORDAN u. CUNNINGHAM, ESQ. CUNNINGHAM & CHERNICOFF P.C. 2320 N. 2ND ST. HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 12121001 11/12/26 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. COMMONWEALTH OF PENNSYLVANIA BUREAU OF EMPLOYEE BENEFIT & SERVICES DATE: 12/13/11 MARK A. LOCKETT, ESQ. BONNER, KIERNAN, TREBACH & CROCIATA EIGHT PENN CENTER 5-200 1628 JOHN F. KENNEDY BLVD. PHILADELPHIA PA 19103 ATTORNEY(S) FOR DEFENDANT N L 12121001 12/26/11 r CARROL PLETCHER Vs. THE TJX COMPANIES, INC., TO: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. A/K/A MARSHALLS Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PERSONNEL DEPARTMENT COMMONWEALTH OF PENNSYLVANIA BUREAU OF EMPLOYEE BENEFIT & SERVICES HARRISBURG FA I/ 1 R*W&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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce tbings 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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR. B COURT: - ?4 thonotary, Civil Division Date:_ Seal f the urt Deputy ISSUED ON: 1/10/12 NO.'10-398 CIVIL ADDENDUM TO SUBPOENA 12121001 1/30/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ALL EMPLOYMENT RECORDS, INCLUDING BUT NOT LIMITED TO ALL EARNINGS AND PAYROLL RECORDS, W-2 FORMS, EMPLOYMENT APPLICATION, PERSONNEL & MEDICAL FILES, PHYSICIAN & PHYSICAL EXAM RECORDS, CORRESPONDENCE, ACCIDENT REPORTS, WORKMEN'S COMP. CLAIMS, INSURANCE RECORDS, TIME CARDS OR ATTENDANCE SHEETS AND ANY OTHER RECORDS IN YOUR POSSESSION OR CONTROL PERTAINING TO CARROL A. PLETCHER NEE CARROL GERLAND AND, CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263). ACCIDENT DATE: 01/21/08, DISABILITY RECORDS; PERSONNEL NUMBER: 515848 BONNER KIERNAN TREBACH & CROCIATA, LLP BY: KEVIN E. MONASTRA, ESQUIRE IDENTIFICATION NO: 91648 EIGHT PENN CENTER, SUITE 200 1628 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEY FOR DEFENDANTS, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. aWa Marshalls) CARROL PLETCHER COURT OF COMMON PLEAS CUMBERLAND COUNTY r'a Plaintiff -ox rv ..-.; V. rqW zrn a x T? THE TJX COMPANIES, INC. a/k/a= M MARSHALLS Defendants NO: 10-398 CIVIL 330 WITHDRAWAL OF APPEARANCE- ? y TO THE PROTHONOTARY: :rte Kindly withdraw my appearance in the above-entitled action on behalf of defendant, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls). TO THE PROTHONOTARY: BONNER KIERNAN TREBACH & CROCIATA, LLP BY: /? , O JENNIFV A. MCOARRITY, ESQUIRE 493037 Attorney for Marmaxx Operating Corp.( improperly designated as The TJX Companies, Inc.) ENTRY OF APPEARANCE Kindly enter my appearance in the above-entitled action on behalf of defendant, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls). BONNER KIERNAN TREBACH & CROCIATA, LLP BY: KEVIN E. MONASTRA, ESQUIRE Attorney for Marmaxx Operating Corp.( improperly designated as The TJX Companies, Inc.) BONNER KIERNAN TREBACH & CROCIATA, LLP BY: KEVIN E. MONASTRA, ESQUIRE IDENTIFICATION NO: 91648 EIGHT PENN CENTER, SUITE 200 1628 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEY FOR DEFENDANTS, Marmaxx Operating Corp. (improperly designated as TtTJ &3 -'" Companies, Inc. a/k/a Marshalls) ? -, COURT OF COMMON PLEA S' CARROL PLETCHER CUMBERLAND COUNTY - Plaintiff r cn rv - THE TJX COMPANIES, INC. a/k/a 1 : ? _ ==l F C s., C MARSHALLS . .„ „ C= . --?` Defendants NO: 10-398 CIVIL - -- ;: CERTIFICATE OF SERVICE I, Kevin E. Monastra, Esquire, hereby certify that on the 9th day of January, 2012, a true and correct copy of the attached Answers and Objections of Defendant, Marmaxx Operating Corp., to Plaintiff's Interrogatories and Requests for Production of Documents, was served via U.S. Mail, First Class, Postage Prepaid, upon the following: Jordan J. Cunningham, Esquire Cunningham & Chernicoff, P.C. 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 BONNER KIERNAN TREBACH & CROCIATA, LLP BY: -?. KEVIN E. MONASTRA, ESQUIRE Attorney for Marmaxx Operating Corp.( improperly designated as The TJX Companies, Inc.) BONNER KIERNAN TREBACH & CROCIATA, LLP BY: MARK A. LOCKETT, ESQUIRE / KEVIN E. MONASTRA, ESQUIRE IDENTIFICATION NO: 50023 / 91648 EIGHT PENN CENTER, SUITE 200 1628 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEYS FOR DEFENDANT, Marmaxx Operating Corp. (Improperly designated as The TJX Companies, Inc. a/k/a Marshalls) CARROL PLETCHER COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff V. THE TJX COMPANIES, INC. a/k/a MARSHALLS Defendants I NO: 10-398 CIVIL OBJECTIONS AND ANSWERS OF DEFENDANT, MARMAXX OPERATING CORP. (IMPROPERLY DESIGNATED AS THE TJX COMPANIES, INC. A/K/A MARSHALLS) TO PLAINTIFF'S INTERROGATORIES Defendant, Marmaxx Operating Corp. (Improperly designated as "The TJX Companies, Inc. a/k/a Marshalls") (hereinafter referred to as "Answering Defendant"), by and through their counsel, BONNER KIERNAN TREBACH & CROCIATA, LLP, hereby answers Plaintiff's Interrogatories, as follows: GENERAL OBJECTIONS 1. Answering Defendant objects to Plaintiff's Interrogatories to the extent that the information sought is protected from discovery for any reason including the attorney-client privilege, and/or the attorney work product doctrine, and/or the Pennsylvania Rules of Civil Procedure. 2. Answering Defendant objects to Plaintiff's Interrogatories to the extent that the information sought may be ascertained from an examination of either party's call at trial. Answering Defendant will identify such witnesses in accordance with the deadlines set by the Court. Answering Defendant reserves the right to supplement this answer prior to the close of discovery. 2. State the name, address, and occupation of any person you expect to call as an expert witness at trial. ANSWER: Objection. This interrogatory, coupled with the instructions plaintiff seeks to apply to it seeks discovery beyond that permitted by Pa.R.C.P. Nos. 4003.1 through 4003.5 as the interrogatory: (1) seeks information protected by the attorney client privilege; (2) seeks the disclosure of mental impressions of Answering Defendant's counsel and counsel's conclusions, opinions, memoranda, notes of summaries, legal research or legal theories or other work product; and (3) seeks information regarding Answering Defendant's representatives' mental impressions, conclusions or opinions respecting the value and merit of a claim or defense or respecting strategy or tactics. Answering Defendant further objects to this interrogatory as premature in that Answering Defendant has not yet completed its investigation and discovery is ongoing. Subject to and without waiver of the foregoing objections and the general objections set forth above, Answering Defendant has not selected its expert witness(es) they intend to call at trial. Answering Defendant will identify such expert witnesses and produce their respective expert reports in accordance with the deadlines set by the Court. Answering Defendant reserves the right to supplement this answer prior to the close of discovery. For each such expert, state: (a) The subject matter on which the expert is expected to testify; (b) The substance of the facts and opinions for which he will testify; and (c) A summary of the grounds for his opinion. ANSWER: Answering Defendant directs plaintiff to its objections and answer to Interrogatory No. 2. . n 4. Identify by author, title, and page number what test, journals or other writings provide a basis for the opinions held by each expert or which may in any way be relied upon you at the upcoming trial. ANSWER: Answering Defendant directs plaintiff to its objections and answer to Interrogatory No. 2. 5. List all appearances in Court by each expert for the past ten (10) years. State the subject matter of his testimony and the party for whom he testified. Please also supply a curriculum vitae for each of your experts. Answer: Answering Defendant directs plaintiff to its objections and answer to Interrogatory No. 2. 6. Please identify, any and all fact witnesses who have any knowledge whatsoever pertaining to the issues involved in the instant case, as well as any and all potential witnesses or individuals whom you may call at trial and who have not heretofore been identified, including the name, place, and manner of contact between the potential witnesses and the parties, the substance of the facts to which the witness could testify if called by any party, the method of discovery of the potential witnesses, the purpose of the witness testimony (if applicable), and whether any statement or summary or written memorandum has been taken with respect to the potential witness and if so, who has possession of that statement or document at the present time. (Please attach a copy of the same without the necessity of filing a formal Request for Production of Documents.) ANSWER: Answering Defendant directs plaintiff to its objections and answer to Interrogatory Nos. 1 and 2. By way of further answer, the store manager, Bill Phoenix, has knowledge of facts related to plaintiffs incident. 7. State all admissions against interests you propose to offer as evidence of an admission against the interests of the Defendant herein. Specify the name of the person making the admission, the date of said admission, the person or persons to whom said admission was made, and the person or persons who were present at the time of making said admission. ANSWER: Objection. This interrogatory, coupled with the instructions plaintiff seeks to apply to it seeks discovery beyond that permitted by Pa.R.C.P. Nos. 4003.1 through 4003.5 as the interrogatory: (1) seeks information protected by the attorney client privilege; (2) seeks the disclosure of mental impressions of Answering Defendant's counsel and counsel's conclusions, opinions, memoranda, notes of summaries, legal research or legal theories or other work product; and (3) seeks information regarding Answering Defendant's representatives' mental impressions, conclusions or opinions respecting the value and merit of a claim or defense or respecting strategy or tactics. Answering Defendant further objects to this interrogatory as premature in that Answering Defendant has not yet completed its investigation and discovery is ongoing. Subject to and without waiver of the foregoing, at this time, Answering Defendant has not determined the evidence that it intends to introduce at trial. Answering Defendant will identify such evidence in accordance with the deadlines set by the Court. Answering Defendant reserves the right to supplement this answer prior to the close of discovery. 8. State whether the Plaintiffs, their attorney, representative, employee, or any other person acting on Plaintiffs' behalf, obtained statements in any form, whether written, stenographic, mechanical, electrical, or any other recording devise (hereinafter called "statements"), or a transcript thereof from any person regarding any matter or thing concerning this action or its subject matter. If so, state: (a) The name and address of the person from whom such statements were taken; (b) The dates on which such statements were taken; (c) The names and addresses of the persons and employees of such persons who took such statements; (d) The names and addresses of the persons having custody of such statements; (e) Whether such statements were written by recording devise, by Court Reporter, or stenographer; (f) Whether such statements were signed; and (g) Attach a photostatic copy or like reproduction of each statement. ANSWER: Objection. This interrogatory, coupled with the instructions plaintiff seeks to apply to it seeks discovery beyond that permitted by Pa.R.C.P. Nos. 4003.1 through 4003.5 as the interrogatory: (1) seeks information protected by the attorney client privilege; (2) seeks the disclosure of mental impressions of Answering Defendant's counsel and counsel's conclusions, opinions, memoranda, notes of summaries, legal research or legal theories or other work product; and (3) seeks information regarding Answering Defendant's representatives' mental impressions, conclusions or opinions respecting the value and merit of a claim or defense or respecting strategy or tactics. Subject to and without waiver of the foregoing objections and the general objections set forth above, Answering Defendant directs plaintiff to the statements contained in the claims file produced in response to plaintiffs Requests for Production of Documents. 9. State the names and addresses of the person answering these Interrogatories. ANSWER: Paul Kangas, Senior Vice President, Chief Compliance Officer, with the assistance of counsel. T0. Has any other individual or individuals been injured in any of the stores you manage as the result of the collapse of displays, movement of displays, of falls within the past five(S) years? If so, for each such incident, state: (a) The date of the incident; (b) Describe the circumstances that surrounded the incident; (e) Address of the premises on which the incident occurred; (d) The caption of each suit arising out of such incident; and (e) Resolution of each such matter. ANSWER: Objection. Answering Defendant objects to this interrogatory as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this interrogatory as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. 11. Please state the name, address, and telephone number of each employee who was present on the premises on the date the accident occurred? ANSWER: Answering Defendant directs plaintiff to the employee list produced in response to plaintiffs Requests for Production of Documents. 12. Please state whether any witness, employee, or agent of the Defendant gave any statement concerning the incident. For each such statement, state: (a) the name and address of the person who gave the statement; (b) the name and address of the person who took the statement; (c) the substance of each oral statement or attach a copy of the written statement; (d) if the statement is written, state the name and address of the person who has custody or control of the statement ANSWER: Answering Defendant directs plaintiff to the statements contained in the claims file produced in response to plaintiffs Requests for Production of Documents. 13. Were any photographs taken of the accident scent by any agent for Defendant? If so, for each such photograph, state: (a) the date and time it was taken; (b) the name and address of the person who took the photograph; (c) the name and address of the person who has control and custody of the photograph; and (d) attach a copy of each such photograph. ANSWER: No. 14. Was an inspection of the accident scene made by any employee or agent for the Defendant subsequent to the accident? If so, for each inspection, state: (a) the date and time the inspection was performed; (b) the name, address, and position or title of the person who made the inspection; (c) the substance of any oral inspection; and (d) a copy of any written inspection. ANSWER: Objection. This interrogatory, coupled with the instructions plaintiff seeks to apply to it seeks discovery beyond that permitted by Pa.R.C.P. Nos. 4003.1 through 4003.5 as the interrogatory: (1) seeks information protected by the attorney client privilege; (2) seeks the disclosure of mental impressions of Answering Defendant's counsel and counsel's conclusions, opinions, memoranda, notes of summaries, legal research or legal theories or other work product; and (3) seeks information regarding Answering Defendant's representatives' mental impressions, conclusions or opinions respecting the value and merit of a claim or defense or respecting strategy or tactics. Subject to and without waiver of the foregoing objections and the general objections set forth above, no. 15. Did you receive notice of this incident from the Plaintiff? If so, state: (a) the date, time, and place you received notice; (b) whether the notice was written or oral. If the notice was written, please attach a copy of such notice together with the name and address of the person in custody and control of such notice. ANSWER: Yes. Sometime after the incident, store manager, Bill Phoenix was informed by plaintiff that she fell. 16. Did you receive notice of the incident from any other person? If so, state: (a) the date, time, and place you received notice; (b) the name, address, and title of the person from whom you received such notice; (c) whether the notice was written or oral. If the notice was written, please attach a copy of such notice together with the name and address of the person in custody and control of such notice. ANSWER: No. 17. Plaintiff alleges that a display of chairs, a table, and other products were placed on a movable platform, the base of which platform was approximately three (3) to five (5) inches from the floor and mounted on wheels allowing for movement of the display. Plaintiff is of the opinion the wheels mounted to the platform were not in a locked position and as a result when an item was lifted from the display became entangled with the display, the display moved causing her to fall and injure herself Do you contend that such occurrence did not cause the Plaintiff to fall? ANSWER: Objection. Answering Defendant objects to this interrogatory as it assumes certain facts that have not been proven by plaintiff. Subject to the foregoing objection and the general objections set forth above, yes, plaintiffs fall was caused by her own negligence. 18. If your answer to the proceeding Interrogatory is in the affirmative, state what you believe caused the Plaintiff to fall and what facts you base such contention on. ANSWER: Answering Defendant directs plaintiff to its objection and answer to Interrogatory No. 17. 19. Did you or any agent or employee receive any complaint, warning, or other notice from other customers concerning displays placed on platforms which were not stable or moved at anytime in the past ten (10) years? If so, state: (a) the date and time it was received; (b) whether it was written or oral. If such complaint, warning or other notice was oral, please describe the substance of it. If written, please attach a copy of such complaint, warning or other notice; (c) the name and address of person making such complaint, warning or other notice; (d) the name, address, and title of the person receiving such complaint, warning, or other notice. ANSWER: Objection. Answering Defendant objects to this interrogatory as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this interrogatory as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. Subject to and without waiver of the foregoing objection, Answering Defendant did not receive any complaints regarding the display plaintiff allegedly fell over prior to her fall. 21. Has any other accident occurred on your premises or other premises you own or manage in the same area as, or in a similar manner to, the accident in which Plaintiff was injured? If the answer is in the affirmative, state: a. the date and time of the occurrence; b. description of how it occurred; c. the names, addresses, and contact numbers of the person(s) to whom the incident was reported and person(s) who witnessed the incident; d. location of the incident; e. whether any safety precaution was taken as a result of it and, if so, a description of such safety precaution; and f. copy(ies) of any written report(s) of the incident and subsequent measures taken as precautionary measures. ANSWER: Objection. Answering Defendant objects to this interrogatory as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this interrogatory as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation and does not contain any time parameters. 22. Have you ever received any notice from a safety consultant, risk manager, or similar professional regarding the use of moveable platforms for display purposes and, if so, what advise, notice, or information did you receive? ANSWER: Objection. Answering Defendant objects to this interrogatory as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this interrogatory as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation and does not contain any time parameters. BONNER KIERNAN TREBACH & CROCIA.TA, LLP BY: Z C -kL- MARK A. LOCKETT, ESQUIRE KEVIN E. MONASTRA, ESQUIRE Attorneys for Defendant, Marmaxx Operating Corp. (Improperly designated as "The TJX Companies, Inc. a/k/a Marshalls") BONNER KIERNAN TREBACH & CROCIATA, LLP BY: MARK A. LOCKETT, ESQUIRE / KEVIN E. MONASTRA, ESQUIRE IDENTIFICATION NO: 50023 / 91648 EIGHT PENN CENTER, SUITE 200 1628 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEYS FOR DEFENDANT, Marmaxx Operating Corp. (Improperly designated as The TJX Companies, Inc. a/k/a Marshalls) CARROL PLETCHER Plaintiff V. THE TJX COMPANIES, INC. a/k/a MARSHALLS Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-398 CIVIL OBJECTIONS AND RESPONSES OF DEFENDANT, MARMAXX OPERATING CORP. (IMPROPERLY DESIGNATED AS THE TJX COMPANIES, INC. A/K/A MARSHALLS) TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS Defendant, Marmaxx Operating Corp. (Improperly designated as "The TJX Companies, Inc. a/k/a Marshalls") (hereinafter referred to as "Answering Defendant"), by and through their counsel, BONNER KIERNAN TREBACH & CROCIATA, LLP, hereby answers Plaintiff's Requests for Production of Documents and Things, as follows: GENERAL OBJECTIONS Answering Defendant objects to Plaintiff's Requests for Production of Documents to the extent that the information sought is protected from discovery for any reason including the attorney-client privilege, and/or the attorney work product doctrine, and/or the Pennsylvania Rules of Civil Procedure. 2. Answering Defendant objects to Plaintiff's Requests for Production of Documents to the extent that the information sought may be ascertained from an examination of either party's records, those records that are publicly available to each party, the review of documents produced in this litigation and/or those documents in which the burden of obtaining the information is substantially the same for Answering Defendant as for Plaintiff. 3. Answering Defendant objects to the instructions contained in Plaintiff's Requests for Production of Documents to the extent that the instructions impose or purport to impose upon Answering Defendant requirements not otherwise provided by or contained in the Pennsylvania Rules of Civil Procedure. 4. Answering Defendant objects to Plaintiff's Requests for Production of Documents to the extent that they are unreasonable, oppressive, unduly burdensome and require the making of unreasonable investigation in contravention of the Pennsylvania Rules of Civil Procedure. 4;. Answering Defendant objects to Plaintiff's Requests for Production of Documents and their instructions and definitions to the extent that they require supplemental answers in contravention of Pennsylvania Rules of Civil Procedure 4007.4. 6. Discovery is ongoing and Answering Defendant may continue to investigate the facts and circumstances alleged in Plaintiff's Complaint. To the extent that additional information is uncovered, Answering Defendant reserves the right to modify these answers as necessary. y. Answering Defendant objects to the time frame of these requests as overly broad and burdensome insofar as it does not specify a beginning date and may include time periods that far precede Answering Defendant's services allegedly at issue in this litigation. GENERAL CONDITIONS Answering Defendant asserts the following conditions with respect to its Objections and Answers to Plaintiff's Requests for Production of Documents: 1. When responding to any and all requests, Answering Defendant expressly reserves the right i. to object to the admissibility at trial of any information supplied as a result of any such response and/or to the admissibility at trial of any documents referenced therewith; and ii. to modify any of the said answers objections at a later date if further factual development or analysis warrants such modification or if additional documents are located which are properly called for by Plaintiff's discovery requests. 2. All terms in Plaintiff's Requests for Production of Documents have been given their usual and customary meaning and these answers and objections have been prepared in accordance with the Pennsylvania Rules of Civil Procedure rather than in accordance with any instructions or purported instructions contained in Plaintiff's Requests for Production of Documents. REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS 1. Please provide written guidelines for the construction or placement of displays on the sales floor. RESPONSE: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence and it is vague, ambiguous and overly broad because it fails to specify the "displays" to which it is referring and plaintiffs incident only involves a particular "display". Subject to and without waiver of the foregoing objections and the general objections set forth above, Answering Defendant directs plaintiff to the Marshalls Display Guidelines produced herein. 2. Copies of any incident reports over the past five years concerning injuries received from sales floor displays at any of the stores Defendants(s) operate or manage. RESPONSE.: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this request as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. 3. Copies of any insurance reviews or inspections regarding placement, instructions, or stability of displays set up on the sales floor of any of the stores Defendant operates or manages received from any carriers in the past five (5) years. RESPONSE: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this request as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. Answering Defendant further objects to this request as ambiguous, vague and overly broad because the terms "reviews", "inspections", "placement", "instructions" and "stability" are undefined. Because plaintiff has failed to define these terms with the requisite specificity and without specific information as to what plaintiff means by these terms and to what it is referring, at this time, Answering Defendant is unable to provide a definitive response to this request. 4. Copies of any OSHA reports concerning injuries cause to employees that arose out of or from displays that were set up on the sales floor in any of the stores Defendant operates or manages in the past five (5) years. RESPONSE: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this request as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. 5. Reports of injuries by employees cause by displays which were set up on the sales floor in any of the stores Defendant operates or manages by the Defendant issued within the past five (5) years. RESPONSE: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this request as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. 6. Reports or letters received within the past five (5) years from members of the public regarding or complaining about any incidents or injuries caused to them or too third parties by displays set up on the sales floor at any of the stores owned, operated, or managed by the Defendant. RESPONSE: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this request as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. 7. Written guidelines or instructions issued by the Defendant to store managers of stores owned, operated or managed by the Defendant regarding the placement of store display or instructions regarding the construction of store displays issued in the past five years. RESPONSE: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence and it is vague, ambiguous and overly broad because it fails to specify the "displays" to which it is referring and plaintiffs incident only involves a particular "display". Subject to and without waiver of the foregoing objections and the general objections set forth above, Answering Defendant directs plaintiff to the Marshalls Display Guidelines produced herein. 8. Copies of any video tapes or pictures of the incident or accident scene involving the Plaintiff. RESPONSE: None. 9. Copies of any accident or incident report regarding Ms. Pletcher's accident. RESPONSE: Answering Defendant directs plaintiff to the claims file produced herein. 10. Statements given by either any employee of the store or third party witnesses regarding Plaintiff's accident. RESPONSE: Answering Defendant directs plaintiff to the claims file produced herein. 11. Any photograph's or video tapes of the accident scene taken at or near the time of the accident or any video tape or any pictures taken of the display at or near the display at the time of the accident. RESPONSE: None. 12. Copies of any statement given by Ms. Pletcher to the manager or other employees of the store or to any insurance representative concerning how the accident happened and any injuries that she sustained. RESPONSE: Answering Defendant directs plaintiff to the claims file produced herein. 13. Copies of any disciplinary action taken against any employees arising out of the accident involving Plaintiff. RESPONSE: None. 14. Since Plaintiff's accident, any written changes or instructions to the stores which Defendant owns, operates or manages as to the construction and/or placement of displays on the sales floor. RESPONSE: Objection. Answering Defendant objects to this request as it seeks information not reasonably calculated to lead to admissible evidence. Answering Defendant further objects to this request as vague, ambiguous and overly broad because it seeks information regarding stores other than the store at issue in this litigation. Subject to and without waiver of the foregoing objections and the general objections set forth above, none. BONNER KIERNAN TREBACH & CROCIATA, LLP BY. MARK A. LOCKETT, ESQUIRE KEVIN E. MONASTRA, ESQUIRE Attorneys for Defendant, Marmaxx Operating Corp. (Improperly designated as "The TJX Companies, Inc. a/k/a Marshalls") JAN-06-2012 FRI 11:49 AN FAX NQ. P. 02102 VEfflFICATION The undersigned, having read the foregoing Answers & Objections of Defendant., Marmaxx Operating Corp., to Plaintiffs Interrogatories and Responses to Plaintiff s Request 'for Production verifies that the responses arc based on information funzished to counsel, which information has been gathered by counsel in the course of this lawsuit. The language of the pleading is that of counsel and not of signer. Signer verifies that he has read the foregoing Answers & Olajeetions of Defendant, Marmaxx Operating Corp., to Plaintiff's Interrogatories and Responses to Plaintiff's Request for Production, and they are true and correct to the best of the signer's knowledge, information and belief. To the extent that the contents of the foregoing document are that of counsel, verifier has relied upon counsel in making this verification; that the facts stated therein have been assembled by authorized agents, employees, and counsel, and signer is informed that the facts stated therein are true. This verification is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. PAUL KATA,SI Sr. Vice Pre ' ent, Chief Compliance Officer Dated: Pletcher V. Marmaxx operating Corp, 0460,0126 (Page 1 of 2) Fono- 0 a0ncloro n -0 p00, rDm D f? O A _0 n <x 2or-oc, t°vr?A:0 ? W z b < - b Ln C 0 s 0 z ru 3 -I r- z > CD m z m 0) c J :D C) A y ° o 0 OD o m ° 0 v ? J D m z C 3 W m 0 0 0 CD C7 x a 00 O N 0 0 0 0 T y cr Tro A ? ro tdrog;s W 0 fD 00 r+ n p = 30-0er 0 ±a 0 (yq ptAp `O c td ,. ?p T tp G ro 0 n 0 ro c--)1-4 T x c< ?m 3 C X? CA" C N M mW 0 ODO O M m m-0 .aX A ^1 ? fJ1 r U) M 00 Q `Z W A ' Ul 3.6 ri N .? O cn d R end? 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CA CP0 t r W ao;DD r C.)" c v 4' Z m? r ( n - r c) <n' : ° M" a 3 Z A D ( r m -0-o c s 0 0 b (n CD a _ Zl a Cw N Z c m p Z4 x ' ? ° Z I m ( fl T al z CT H (n D a o w w y a co w 1 co "O s O Z o -0 C o to m 4 H C O Z O C7 C (n a c U 3 D D 0 A O n n 0 +? 3 Z D--< DM rZ a' - i Q m `c m g Zrd0 am m o 0 7 m 03 c 7 C co 3 m i a - O I-? wo 010 d m o w 0. 30 we 3 ?m a 3m m?cD mm z rn m_M P! C-) C cOO O' H -1 (n ZO OD a 0-0 r D zo :cw - i x M M c);u L z -i (nr-N xc m X r m n c - r M Om o H -? -1 S p .Z7 O aZ Z m D .+ X 0 3 O Dm !D I ? n Z1 ' > t1 D A n 2 co CA3 o m m cr n " w ? O CT x x m m N W ? z m m co 'a 'a V mm? m M V m m 0 < < < 333 a a a a a a 0. c om Qy ,? 0. ID CL a aZZZ m m3 .0 <m 29 w3 O ? D,mm 0 (a 333 a 0 y,V z w 0 CO to W m O m :a'O CO N 3 O O X C C-) X ;0 X O 0) - G (7 2 X x D S H.ji I > rr.. ro tes v, rw om O OM ? D =z i r H rm a C) a ?i c CD O z n . rn m z %C V p a ?N cr 3 o -1 Z rn m 0 0 n m 3 Q Z G p 0 n 7 D n D 11 D T 1 J n n n i f i m n 7 (n n DI B a 2 O N N t0 A m V a) n m tD Z is to a) 0 o? A oa w n a 3 7 a -)a N a O M C m ? ad . O Om N P. - N O C)D (Page 1 of 2) 0 ZURICH January 20, 2009 Carol Pletcher 103 June Drive Camp Hill, 17011 RE: Claim Y: 9640164893 Insured: TJZ Companies, Inc Date of Loss: Janualy 21, 2008 Claimant: Carol Pletcher Zurich North America Dear Ms Pletcher: Claims P.O. Sox 4030 1 am contacting you regarding the above doted claim. According to our Rocky Hill, CT records, you were injured as a result of this accident At this time, I would 06067-4030 like to extend an oiler to you in the amount of Five Hundred Dollars ($500) Telephone (800) Z39-4559 in settlement of your claim for any and all personal injuries sustained as a Fax (800) 987 1335 result of this loss. http //www zurichna com Should this oiler be acceptable to you, please sign the enclosed release of person injuries before a notary and return to my, attention in the envelope provided. Kindly respond by February 14.), 2009 as we are unsure of your intentions and whether or not we should keep our file open. If I have not heard from you by February 10, 2009, I «ill consider this matter resolved and close my file accordingly. Please also be advised that you are under no obligation to resolve your claim. We must advise you that the prescribed time for which you can present a claim for personal injuries is two years fi o the date of loss in the State of PA. If your claim has not settled by January 21, 2010 and you wish to continue to pursue the claim, you will need to file a claim through the courts to preserve your right to pursue damages beyond the 2 year statue of limitations. I look fo rw-ard to hearing fi-om you. I can be reached Monday through Friday bet veen the hours of 7:00am and 3:30pm (EST), at the number listed below. (Page 2 of 2` January 20, 2009 I'a,,;e 2 Very truly yours, Zurich American Insurance Company Tina I:)oueette CLAIM CASE MANAGER (800) 239-459 17984 (Page 1 of 1) THE LAW OFFICFSOF COLGAN MARZZACCO LLC 130 W. Church Street Suite 100 Dillsburg, PA 17019 ph. 717-502-5000 Ix. 717-502-5050 tf. 800-615.0115 Timothy J Colgan Offices in Dillsburg, Christopher J. Aiarzzacco Harrisburg & York David E, Hershey wwwcmlawl.com Thomas M Clark Paul J. Kovatch Tina Doucette Zurich North America PO Box 4030 Rocky Hill, CT 06067-4030 Re: My Client(s): Your Insured: Date of Loss: Your Claim #: Dear Ms. Doucette: December 18, 2008 Carrol Pletcher Marshalls 01/21/08 9640164893-001 I am writing to advise you that I no longer represent Ms. Pletcher with regard to the above-referenced matter. Please remove me from the distribution of further correspondence. If you need further information, please contact me at the number below. Very truly yours, COLGAN MARZZACCO, LLC. by: Christopher J. Marzzacco CJM/jaz cc: Carroll Pletcher (Pages of I) TfiE LAW OFFICFS Of COLGAN MARZZACCO LIC Tina Doucette Zurich North America PO Box 4030 Rocky Hill, CT 060674030 Re: My Client(s): Your Insured: Date of Loss: Your Claim ##: Dear Tina: 1,10 W Church Street Suite 100 Dillshurg.l'A 17019 ph. 717.502-5000 fx 717-502.5050 if 800-015-0115 April 7, 2008 Carrol Pletcher Marshalls 01/21/08 9640164893-001 Timothy j Colgan Christopher J Jtanzacco David E Hershey Thomas H CJark Paul J. Kovalch Offices in Dillshurg. KArn%hurg & Vork www.cmlaw 1. com I received your March 20, 2008 letter in which you provide your recollection of a telephone conversation you had with my client several weeks after the above-referenced incident. At this time our investigation continues and my client does not admit any fault in this matter. My client continues to treat at this time for her injuries. I will update you on the same in approximately 45 days. If you have any questions or concerns feel free to contact me at the number above. Very truly yours, COLGAN MARZZACCO, LLC. by: Christopher J. h4arzzacco CJMljar cc: Carroll Pletcher z (Page 1 of 1) ZURICH June 23, 2008 Attorney Christopher Marzzacco The Wiley Group 130 West Church Street, STE 100 Dillsburg, PA 17019 Re: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01-21-2008 Claimant: Carol Pletcher Zurich American Insurance Co. RE: Medical Specials and Liability Theory Rocky Hill P.-.1. Box 4030 Rocky Hill, cr Dear Attorney Marzzacco 06067-4030 This will acknowledge your representation of this claim. To properly telephone: (800) 2394559 - evaluate this matter, please forward your client's medical bills and reports Fax: (800) 887- 1335 http:/)www.zurichna.com , proof of lost wages and any other damages. With this material, I would appreciate your theory of liability of our insured. As an alternative with respect to securing medical specials and treatment reports, I am including a medical authorization for your client to sign. Please return the completed authorization in the envelope provided. If you have any questions, please contact me. Please include our claim number on all forms of communication. Very truly yours, Zurich American Insurance Co. Tina Doucette Claim Case Manager 800.239.4559 x7984 (Page I. of 1) 130 W Church Street Suite 100 CD Villsburg, PA 17019 ph. 717-502-5000 THE tAwOFFICES OF N. 717-502.5050 COLGAN /vV ?l?G " A n 7ZACCO tf. 800.615.0115 LLC Timothy). Colgan Christopher J. Marzzacco David E. Hershey Thomas M. Clark Paul J. Kovatch Offices in Dillsburg, Harrisburg & York www.cmlxwl.com June 26, 2008 Tina Doucette Zurich North America PO Box 4030 Rocky Hill, CT 06067-4030 Re: My Clients): Carrol Pletcher Your Insured: Marshalls Date of Loss: 01/21108 Your Claim #: 9640164893-001 Dear Tina: In response to your letter of June 23, 2008, please be advised that we will provide our theory of liability, medical records and all other evidence of damages upon Ms. Pletcher's completion of treatment. My client continues to treat at this time for her injuries. 1 will update you on the same in approximately 45 days. if you have any questions or concerns feel free to contact me at the number above. Very truly yours, COLGAN MARZZACCO, LLC. i by: Christopher J. Marzzacco CJM/jaz cc: Carroll Pletcher (Page 1 of 1) ZURICH October 2, 2008 Attorney Christopher Marzzacco The Wiley Group 130 West Church Street, STE 100 Dillsburg, PA 17019 Re: Claim 4: Insured: Date of Loss: Claimant: Zurich American Insurance Co. Other: 9640164893-001 Marshalls 01-21-2008 Carol Pletcher Medical Specials and Liability Theory Rocky Hill P 0 Box 4030 Focky Hill, CT Dear Attorney Marzzacco: j6067-4030 I wrote you on June 23, 2008 and requested you provide documentation regarding Telephonxe:i800j623394559 your client's losses. To date, we have not received copies of any medical http:lfwww.zurichna.com reports, bills, hospitalization records, or lost wages, if applicable. The progress of this claim cannot be continued until we are in receipt of the above items. If you have any questions, please contact me. Please include our claim number on all forms of communication. Very truly yours, Zurich American Insurance Co. Tina Doucette Claim Case Manager 800-239-4559 x7984 (Page 1 of 1) 130 W. Church Street Suitc 100 Dillsburg, PA 17019 ph. 717-502-5000 THE VW OFFICES OF fx. 717-502-5050 COLLVt1 AN MARZZACCO if. 800.615-0115 LLC Timothy J. Colgan Christopher). Marzzacco David E. Hershey Thomas M Clark Paul J. Kovatch Offices In Dillsburg, Harrisburg & York wvvw_cmlaw l .cum October 30, 2008 Tina Doucette Zurich North America PO Box 4030 Rocky Hill, CT 06067-4030 Re: My Client(s): Carrol Pletcher Your Insured: Marshalls Date of Loss: 01/21108 Your Claim #: 9640964893-009 Dear Ms. Doucette: I am writing to confirm receipt of your October 2, 2008 letter. With regard to your request for medical records, reports, bills and lost wage information, as indicated in the past, I will provide the same to you when we submit the demand letter. As indicated before, my client is still treating for her injuries. Once we have collected all documentation, I will contact you to give you an idea of when you should expect a demand package from us in this claim. If you have any questions or concerns, feel free to contact me at the number above. Very truly yours, COLGAN MARZZACCO, LLC. by: Christopher J. Marzzacco CJM/jaz cc: Carroll Pletcher (Page 1 of 1) ZURICH November 6, 2008 Attorney Christopher Marzzacco The Wiley Group 130 West Church Street, STE100 Dillsburg, PA 17019 Re: Claim #: 9640164893-001 Insured: The TJX Companies, Inc. Date of Loss: 01-21-2008 Claimant: Carol Pletcher Zurich American Insurance Co. Other: Claim Status Rocky Hill P.O. Box 4030 Rocky Hill, CT Dear Attorney Marzzacco 06067-4030 Please be advised that we reviewed our file and found that there has been Telephone: (800) 239-4559 no contact with your office in quite some time. Fax: (800) 887-1335 http./Mrww.zur ichna.com Please contact the undersigned to advise whether a claim is still being pursued on behalf of your client. If a claim is being pursued, please have your client sign and return the attached authorizations and forward any and all specials in this regard. If a claim is not being pursued, please forward your release of lien, so we might close our file. If you have any questions, please contact me. Please include our claim number on all forms of communication. Very truly yours, Zurich American Insurance Co. Tina Doucette Claim Case Manager (800) 239-4559 x7984 Enclosures Medical Authorization (Page Y of 1) 0 ZURICH Zurich North America February 27, 2008 Attorney Christopher Marzzacco The Wiley Group, Attorneys at Law 130 West Church Street, Suite 100 Dillsburg, PA 17019 RE: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01/21/08 Claimant: Carol Pletcher Your File #: (number) Dear Mr. Marzzacco: Maims P 0 Box 4030 This will acknowledge receipt of your letter, dated February 20, 2008, regarding the Rocky Hill, CT above claim. 06067-4030 Telephone (800) 239-4559 It is requested that the undersigned be given an opportunity to speak with your client Fax (800) 887-1335 regarding the facts of this accident. This statement can be taken over the telephone; http llwww zurichna.com however, if that is not acceptable to you, a representative can meet with you to obtain this statement. Please call me upon receipt of this letter so we may schedule a convenient date and time for taking this statement. I look forward to hearing from you in the very near future. If you have any questions, please contact me. Please include our claim number on all forms of communication. Very truly yours, Zurich American Insurance Company Tina Doucette (800) 239-4559 x7984 (Page 1 of 1) 0 ZURICH March 20, 2008 Attorney Christopher Marzzacco The Wiley Group 130 West Church Street, STE 100 Dillsbury, PA 17019 RE: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01/21/08 Zurich North America Claimant: Carol Pletcher Claims Dear Mr. Marzzacco: P.O Box 4030 Rocky Hill, CT 06067-4030 1 am writing as a follow up to our telephone conversation earlier today. As discussed, on February 6, 2008 at 2:16:24pm, Ms. Pletcher provided a 2394559 Fax Telephone (800) 887--1335 (800) verbal account of the details concerning her accident. http //vvww zurichna.com Your client indicated to us that she visited the Marshall's and found a coverlet for her bed. She noticed two gold pillows on a platform display and leaned in to get a better look at the pillows. This caused Ms Pletch to fall into the display. She hit her head on a crystal lamp, which was located on a table; the lamp fell off the table. Ms. Pletcher said that after falling forward, she fell backward and hit her head again on the floor. Please contact me once you have had the chance to speak with Ms Pletcher, as we are unsure of your intention regarding this matter. I am available at the number below, between the hours of 7:00am to 3:30pm, Monday through Friday, Very truly yours, Zurich American Insurance Company Tina Doucette CLAIM CASE MANAGER (800) 239-4559 x7984 (Page 1 of 1) 0 ZURICH Zurich North America Claims P.O Box 4030 Rocky Hill, CT 06C67-4030 Telephone (800) 239-4559 Fax (800) 887-1335 http llwww zurichna com February 21, 2008 Carol Pletcher 103 June Dr Camp Hill, PA 17011 RE: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01/21/08 Claimant: Carol Pletcher Dear Carol Pletcher: We received notice of claim on January 22, 2008. It is our desire to give your claim prompt attention. We are unable to resolve your claim at this time because we need: (X) Completed medical authorization. (X) Your formal statement to determine and clarify all pertinent facts that may affect liability in this case. ( } To inspect the (product/premises) to determine if a defect exists. ( ) To determine whether your injury and/or damages are, in whole or in part, related to the date of loss. We need further explanation. ( } Other: (Describe what else may be needed here.) If you have any questions, please contact me. Please include our claim number on all forms of communication. Very truly yours, Zurich American Insurance Company Tina Doucette CLAIM CASE MANAGER (800) 239-4559 x7984 (Page 1 of 1) 0 ZURICH February 27, 2008 Attorney Christopher Marzzacco The Wiley Group, Attorneys at Law 130 West Church Street, Suite 100 Dillsburg, PA 17019 RE: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01/21/08 Claimant: Carol Pletcher Zurich North America Dear Mr. Marzzacco: Claims We received your letter dated February 20, 2008 regarding the accident of January P.O. Box 4030 21, 2008. Rocky Hill, CT 06067-4030 We are investigating this matter and meanwhile ask that you provide us with the Telephone (800) 239-4559 medical reports and medical bills you have with regard to the treatment of your client Fax (800) 887-1335 for the injuries allegedly sustained in this accident. http://www zurichna.com We will also require evidence of any pecuniary loss suffered by your client. Please provide the name and address of your client's employer, as well as verification of any claimed self-employment. If you have any questions, please contact me, Please include our claim number on all forms of communication. Very truly yours, Zurich American Insurance Company Tina Doucette (800) 239-4559 x7984 Enclosure (Page 1 of 2) Jan M. Wiley David J. Lenox Timothy 1. Colgan Christopher J. Marzxacco THE WILEY GROUP Attorneys at Law Wiley, Lenox, Colgan & Marzzacco, P.C. February 20, 2008 Tina Doucette Zurich North America PO Roo 4030 Rocky I hil. CT 06067-4030 Re: My Client(s): Your Insured: Date of Loss: Your Claim #: Dear 'I-ina: Carrol Pletcher Marshalls 01 /21 /08 9640164893-001 David E. Hershey Thomas M. Clark Paul J. Kovatch I atn writing to indicate that I have been retained to represent Ms. Pletcher against those responsible for causing the above-referenced slip and fall incident. Our preliminary investigation shows that your insured was responsible for causing Ms. Pletcher's injuries. As an update on said injuries, please note that my client is still unable to work and is treating for her head, neck and wrist injuries at this time. At this time, please provide me with the following information: • Surveillance film of the accident; • A copy of the incident report; • A copy of any totes taken white my client was interviewed, and/or a copy of a recorded statement if one was taken. Also. I understand that there is $250.00 available to my client for medical payments. Please send a check to me payable to Ms. Pletcher. I will then forward it to my client. A credit of $250.00 will be given to Zurich when this matter settles in the future. 130 W. Church Street, Suite 100 • Dillsburg, PA 17019 • Phone: (717) 432-9666 - (800) 682-4250 • Fax: (717) 432-0426 Offices in Harrisburg • York • Carbondale www.wiley4u.corn (Page 2 of 2) At this point, all correspondence to my client should be made through my office. If you have any questions or concerns feel free to contact me at the number below. Very truly yours, WILEY. LENOX. COLGAN & MARZZACCO. P.C. by: Christopher J. Marzzacco CJMJaIc cc: Carrol Pletcher (Page 1 of 2) 0 ZURICH February 18, 2009 Carol Pletcher 103 June Dr Camp Hill, PA 17011 RE: Insured: Marshalls Claim No: 9640164893-001 Date of Loss: January 21, 2008 Dear Ms. Pletcher: Zurich North America Please be advised that I have taken over the handling of your file. You no Claims doubt realize that our obligation as an insurer is not to pay for all losses, P.0 Box 4030 but to pay only such losses, which are caused through the fault of our Rocky Hill, CT insured. We must be guided by all the information available to us, 05067-4030 including the details you provided. Telephone (8001239-4559 Fax (800) 887-1335 We wish to make a fair and prompt adjustment on the merits of all of our http)/www zunchna.com claims, but in this instance, we do not feel that our insured is responsible for your injury. According to your statement, you fell into the display while looking at two pillows that were on the display. It appears that you lost your balance and fell into our display. Based on our investigation, we do not find any liability on the store. A previous offer of $500.00 was extended to you with a deadline of February 10, 2009, you did not respond to the adjuster or accept the offer, based on my review of the file I see no liability on our insured for this loss, and will be withdrawing the offer at this time. If you have any questions or wish to discuss this matter further, please contact me at 1-800-239-4559 Ext. 3809. Please include our claim number on all forms of communication. Sincerely, Zurich American Insurance Company Anne L. Barberino Claim Specialist II 800-239-4559 Ext 3809 (Page 2 of 2? February 18, 2004 Page 2 (Page 1 of 1) 0 ZURICH February 8, 2008 Carol Pletcher 103 June Dr Camp Hill, PA 17011 RE: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01/21/08 Claimant: Carol Pletcher Zurich North America Dear Ms. Pletcher: Claims As per our telephone conversation of February 6, 2008, please be advised P.0 sox 4030 Rocky Hill, CT that I will be conducting an investigation into this incident on behalf of 06067-4030 Marshalls. Telephone (800) 239-4559 Fax (800)88 8877-1335 Please find enclosed a medical authorization form to be completed and http F/www.zurichna com returned to our office. I will be in contact with you as soon as my investigation has been completed. If you have any questions regarding completion of the form, please contact me. Please include our claim number on all forms of communication. Thank you for your assistance. Very truly yours, Tina Doucette CLAIM CASE MANAGER (800) 239-4559 x7984 (Page 1 of 1) 0 ZURICH February 6, 2008 Carol Pletcher 103 June Dr Camp Hill, PA 17011 RE: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01/21/08 Claimant: Carol Pletcher Dear Ms. Pletcher: Zurich North America This will follow our telephone conversation of February 6, 2008 during which we Maims discussed the above-mentioned claim. P.O. Box 4030 Rocq Hill, CT 05067-4030 We are the liability insurance carrier for Marshalls and are currently conducting an investigation into the circumstances surrounding the loss on or about January 21, Telephone (800) 239-4559 2008. We regret to hear that you were injured on our insured's premises, and hope Fax (800) 887-1335 that you will have a speedy recovery. httpAwww Zurich na.com As we discussed, our insured carries medical payments coverage in the amount of $250. This coverage allows us to pay for reasonable and necessary medical expenses incurred as a result of accidents occurring on our insured's premises. Please feel free to forward the medical bills to my attention for review and consideration under our insured's medical payments coverage. Thank you for your cooperation in this matter. Once again, we hope you will be feeling better in the near future. If you have any questions or wish to discuss this matter further, please feel free to contact me. Please include our claim number on all forms of communication. Very truly yours, Zurich American Insurance Company Tina Doucette CLAIM CASE MANAGER (800) 239-4559 x7984 (Page I of -'.) 0 ZURICH January 23, 2008 Carol Pletcher 103 June Dr Camp Hill, PA 17011 RE: Claim #: 9640164893-001 Insured: Marshalls Date of Loss: 01/21/08 Claimant: Carol Pletcher Zurich North America Dear Carol Pletcher: Claims We regret to hear of your injury, please contact me so that we can discuss P O Box 4030 Rocky Hill, CT your claim. 06057-4030 I look forward to hearing from you. I can be reached Monday through Fax Telephone (800)887--1335 (800) 4535 Friday between the hours of 7:30am and 3:30Pm (EST), at the number http://Www.zurichna.com listed below. Very truly yours, Zurich American Insurance Company Tina Doucette CLAIM CASE MANAGER (800) 239-4559 x 7984 Page 1 of 2 Expanded Notes Clain?: 9640164393 Drac: o, 1-oss: 01-21-?.008 Insurers: The TJX Coil ioanies. Inc.. Title: CIID Date Entered: 01-23-200810:30:58 Author: Tina Doucette Category: COVERAGE Distribution Code: None Confidentiality: Insured Name: The TJX Companies, Inc. Address: 770 Cochituate Road City: Framingham State: MA Zip Code: 01701 Policy Information Policy Number: 4020145 Symbol: GLO Module: 00 Effective Date: 07-01-2007 Expiration Date: 07-01-2008 Policy Symbol Description: General Liability - Occurrence Producer Number: 18251000 Producer Name: WILLIS OF MASSACHUSETTS, INC. Producer Phone: (617)437-6900 Policy Status: ACTIVE Cancellation Date: Cancellation Reason: Inception Date: 07-01-2007 Reinsurance Indicator: BOP Indicator: N SIR Indicator: Company Code: 01 Company Name: Zurich American Insurance Co. Best Coverage Source: PRIDE Underwriting Information Organization Type Organization Name Business Unit Zurich Global Corporate Sub Business Unit Casualty Profit Center Domestic Casualty Region Northeast Office Boston No Title: ISO Search Date Entered: 01-22-2008 11:30:51 Author: Danielle Dassero Category: INVESTIGATION Distribution Code: ..None Confidentiality: Yes ISO matches found and sent to Claim Professional via CWS for review. Title: Guest stopped and looked at pillow on Date Entered: 01-22-2008 05:31:26 Author: Matt Bellot Category: 800 REPORTING Distribution Code: None ; Confidentiality: No Guest stopped and looked at pillow on furniture platform when she went forward boot caught platform guest hit her head on lamp and scratched her wrist. Reported by: Bill Phoenix Reported by phone: 7177660133 Insured contact name: Bill Phoenix Insured contact phone: 7177660133 Channel reported: PHONE CSR Name: Matt Bellot Title: Reporter stated that she stated that Date Entered: 01-22-2008 05:31:26 Author: Matt Bellot Category: 800 REPORTING Distribution Code: None Confidentiality: No . >r?r VIL, http://myzuric ,i.zurichna.coin/eZAccess/Access/pagingNotesExpandedNotes.do?selectedP... 4/30/2010 Page 2 of 2 Reporter stated that she stated that she couldn't drive and they called a friend to pick up customer. Also stated that she was parked in Handicap parking lot area, but did not appear to be handicapped. What did you observe She was on the floor If the loss involved a fall, what footwear did the customer(s) have on Stylish boots What was the customer(s) carrying if anything Two bags, carry bag and mars hall bags Height and weight of customer(s): 5'-5"-5'-7" unkn 55yrs Was the customer(s) shopping alone Yes If there is a witness, what is their home phone N/A Was the witness a customer or an employee N/A Was a photo taken No Does the customer(s) need to be contacted immediately Yes If the customer needs contacted immediately, why when she left stated nausea, and good PR Was the loss resolved at the store Yes Was the customer(s) okay when they left the store Believe so What is the exact time of the loss 3:05 pm When will the store manager be working again 1/22/081pm « Previous 1-20 21-40 41-60 61-80 81-100 101-120 121-124 http://myzuric l.zuiicluia.com/eZAccess/Access/pagingNotesExpandedNotes.do?selectedP... 4/30/2010 CARROL PLETCHER VS. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PLAINTIFF/S THE TJX COMPANIES, INC., A/K/A MARSHALLS DEFENDANT/S COURT OF COMMON PLEAS NO. 10-398 CIVIL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 01122029 c_:i tom. ? : ?r AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 2/20/12 ?4&( MARK A. LOCKETT, ESQ. ATTORNEY FOR DEFENDANT 0960.126 4. , CARROL PLETCHER COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PLAINTIFF/S VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS DEFENDANT/S COURT OF COMMON PLEAS NO. 10-398 CIVIL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JORDAN J. CUNNINGHAM, ESQ. CUNNINGHAM & CHERNICOFF P.C. 2320 N. 2ND ST. HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 01122029 12/12/25 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. CARDIOLOGY DIAGNOSTIC ASSOC. DIGESTIVE: DISEASE INSTITUTE MILTON S. HERSHEY MEDICAL CENTER PENN STATE HEART & VASCULAR INSTITUTE PENN STATE HERSHEY MEDICAL CENTER DEPARTMENT OF PULMONARY MEDICINE KARASON PODIATRIC CENTERS INC. KUNKEL SURGICAL GROUP MOFFITT HEART AND VASCULAR GROUP ORTHOPEDIC SURGEONS OF CENTRAL PENNSYLVANIA LTD. PENNSYLVANIA GASTROENTEROLOGY PATHOLOGY ASSOCIATES OF CENTRAL PA. PATHOLOGY ASSOCIATES OF CENTRAL PA. PINNACLE HEALTH HOSPITAL DATE: 1/16/12 MARK A. LOCKETT, ESQ. BONNER, KIERNAN, TREBACH & CROCIATA EIGHT PENN CENTER S-200 1628 JOHN F. KENNEDY BLVD. PHILADELPHIA PA 19103 ATTORNEY(S) FOR DEFENDANT 01122029 12/25/12 CARROL PLETCHER Vs. THE TJX COMPANIES, INC., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND A/K/A MARSHALLS. FileN Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF CARDIOLOGY DIAGNOSTIC ASSOC. 25 MONUMENT RD. TO: YORK PA 17403 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: 1"ELrPHUNE: FOR INFORMATION: (215) 241-5858 SUPREME COURT DD # ATTORNEY FOR DEFENDANT Date:_ /,2s ]/? -Sea( of the tourt ISSUED ON: 2/20/12 BY on evil Division Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA; DOB 04/17/52, SSN XXX-XX-1263) N 011'?_2029 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Vs. THE TJX COMPANIES, INC., A/K/A MARSHALLS, FileNa. Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF DIGESTIVE DISEASE INSTITUTE 899 POPLAR CHURCH RD. TO: _CAMP HILL PA 17011-2206 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR D E D?tc: 1 as ?a "Seal of the Court ISSUED ON: 2/20/12 B CO T: ono o , Civil Division Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) :BX\ C1122029 12.%.25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398 CIVIL File No. THE TJX COMPANIES, INC., A/K/A MARSHALLS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT MILTON S. HERSHEY MEDICAL CENTER 500 UNIVERSITY DR. TO: P.O. BOX 850 HERSHEY PA 17033 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of co=pliance, 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 TEE FOLLOWING PERSON: NAME: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: D EF EN DAN T Date: 1,4:511..2 S of th,. Court ISSUED ON: 2/20/12 Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS 01122029 12/25/12 ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI' S /CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) JN 01122029 12/''5/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398 CIVIL THE TJX COMPANIES, INC., A/K/A MARSHALLS File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PENN STATE HEART & VASCULAR INSTITUTE 500 UNIVERSITY DR., TO: _ P.O. BOX 850 HERSHEY PA 17033 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (Address) You may deliver or mail legble 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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR-- DEFENDItIT BY THE T• no , Ci 'Division Date: ? as )? Deputy -Sea of the Court ISSUED ON: 2/20/12 NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) A 01122029 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Vs. THE TJX COMPANIES, INC., A/K/A MARSHALLS Court of Common Pleas 10-398 CIVIL File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PENN STATE HERSHEY MEDICAL CENTER DEPARTMENT OF PULMONARY 'MEDICINE TO: 500 UNIVERSITY DR. P.O. BOX 850 HERSHEY (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: 1r,Ltt'riUNh: FOR INFORMATION: (Z15) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT Date:_ 2/20/12 Seal of the Court BY THE URT: 47W'notary, C' ' Division Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) 011.22029 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas Vs. 10-398 CIVIL THE TJX COMPANIES, INC., A/K/A MARSHALLS File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF KARASON PODIATRIC CENTERS INC. 801 E. PARK DR. TO: HARRISBURG PA 17111 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME CTHMNDANT ATTORNEY FOR: Date:_ J IdS11-:? Seal of th Court ISSUED ON: 2/20/12 BY THE OURT: onotaryCivil Division Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) 011?2029 12/25/12 CARROL PLETCHER Vs. THE TJX COMPANIES, INC., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND A/K/A MARSHALLS Court of Common Pleas 10-398 CIVIL File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF KUNKEL SURGICAL GROUP 890 POPLAR CHURCH RD. S-210 TO: CAMP HILL PA 17011 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (2.15) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEkENDANT Date: f o?,S 11.412- Seat of the urt ISSUED ON: 2/20/12 BY TH7T. P ro , Civil D' ' ion Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) N 01122029 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Vs. , THE TJX COMPANIES, INC., A/K/A MARSHALLS, File No. Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF MOFFITT HEART AND VASCULAR GROUP 1000 N. FRONT ST. TO: WORMLEYSBURG PA 17043 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: lnl-trHuNh: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANI: Date:_ r o? S 11,2 Seal of thetourt ISSUED ON: 2/20/12 BY THE C T: Pro tart', Civil ivision Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS 01122029 12/25/12 ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) 01122029 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398 CIVIL THE TJX COMPANIES, INC., A/K/A MARSHALLS ' File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF ORTHOPEDIC SURGEONS OF CENTRAL PENNSYLVANIA LTD. TO: 550 N. 12TH ST. S-140 LEMOYNE PA 17043 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEYFOR. .. .. Date:_ S ' of the Court ISSUED ON: 2/20/12 BY THE CO T: Pro tary, Ci ivision Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) 01122029 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas Vs. 10-398 CIVIL File No. THE TJX COMPANIES, INC., A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PENNSYLVANIA GASTROENTEROLOGY 899 POPLAR CHURCH RD. TO: CAMP HILL PA 17011 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) SUPREME COURT ID # ATTORNEY FOR: ,sell of Court ISSUED ON: 2120/12 241-5858 BY THE CO to , Civil D' 6 ion Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATIO14 RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) N 01122029 12/25/12 CARROL PLETCHER Vs. THE TJX COMPANIES, INC., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . File No. A/K/A MARSHALLS. Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PATHOLOGY ASSOCIATES OF CENTRAL PA. 100 S. 2ND ST. TO: HARRISBURG PA 17101 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: DE F ENDANT BY THE ?T: P o o ry, Civil ivision Date: 5 of the urt Deputy ISSUED ON: 2/20/12 NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATIO14 RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) 1 01122029 12/25/12 CARROL PLETCHER Vs. THE TJX COMPANIES, INC., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • File No. A/K/A MARSHALLS, Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF PATHOLOGY ASSOCIATES OF CENTRAL PA. 4520 UNION DEPOSIT RD. TO: HARRISBURG PA 17111 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID? ATTORNEY FOR Date: f L-2 Yra Seal of the ourt ISSUED ON: 2/20/12 BY THE CO T: It"/ - Pro , Civil T vision Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA; DOB 04/17/52, SSN XXX-XX-1263) :.22029-. 25/12. CARROL PLETCHER COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Vs. THE TJX COMPANIES, INC., A/K/A MARSHALLS' File No. Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS MEDICAL WA Sq%VAW TRSUANT TO RULE 4009.22 PINNACLE HEALTH HOSPITAL 409 S. 2ND ST. TO: HARRISBURG PA 17104 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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. NAME: _ ADDRESS: THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: MARK A. LOCKETT, ESQ. TELEPHONE: FOR I : 215) 241-5858 SUPREME COURT D)fE ?PTT ATTORNEY FOR: Date:_ / l S of Court ISSUED ON: 2/20/12 BY TE Hotl ary, ivil ivision Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 01122029 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/ CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROLL A. PLETCHER NEE CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA; DOB 04/17/52, SSN XXX-XX-1263) 04102010 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER PLAINTIFF/S VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS DEFENDANT/S COURT OF COMMON PLEAS NO. 10-398 CIVIL try }0'"1 fia C7, 7 C3 -S r- ?C- t , 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, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 5/10/12 A. LOCKETT, ESQ. AT ORNEY FOR DEFENDANT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas 10-398 CIVIL vs. File No. THE TJX COMPANIES, INC., A/K/A MARSHALLS 04102010 12/25/12 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF INTERNISTS OF CENTRAL PA 108 LOWTHER ST. TO: LEMOYNE PA 17043 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION : (215) SUPREME COURT ED # ATTORNEY FOR: DEFENDANT Dace: L11011-9 ' Seal of the Court ISSUED ON: 5/10/12 241-5858 B Civil Divisio Deputy ADDENDUM TO SUBPOENA 04102010 NO. 10-398 CIVIL 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS 8/25/11 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS /CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINKSY) (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) INCLUDING RECORDS FROM MICHAEL L. GLUCK, M.D. AND PATRICK RATNASAMY, M.D. 04102024 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER PLAINTIFF/S VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS DEFENDANT/S f C'J COURT OF COMMON PLEAS yr NO. 10-398 CIVIL C) C_ -i; 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, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 5/10/12 A. LOCKETT, ESQ. NEY FOR DEFENDANT N 04102024 12/25/12 CARROL PLETCHER Vs. THE TJX COMPANIES, INC., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • File No. A/K/A MARSHALLS Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PINNACLE HEALTH HOSPITAL AT POLYCLINIC RADIOLOGY DEPARTMENT TO: 2501 N. THIRD ST. HARRISBURG PA 17110 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) SUPREME COURT ID # ATTORNEY FOR Date: Y IMP A cal f the Court ISSUED ON: 5/10/12 241-5858 BY T: /U Pro , Civil Division Deputy v ? NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 04102024 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL FILMS AND REPORTS PERTAINING TO: CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) 05042018 CARROL PLETCHER COUNTY OF CUMB COMMONWEALTH OF PENNSYLVANIA ERLAND I I A !0: 42 "i 1 B'E6!!R L A N \D1? pC O U N T `lr COURT OF COMMON PLEAS ' 3Lft iJ?'?Y?T1 PLAINTIFF/S ) VS. ) THE TJX COMPANIES, INC., A/K/A MARSHALLS ) DEFENDANT/S ) NO. 10-398 CIVIL 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, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 6/04/12 A. LOCKETT, ESQ. NEY FOR DEFENDANT N 05042018 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF cUMBERL-AND CARROL PLETCHER Court of Common Pleas 10-398 CIVIL VS. File No. THE TJX COMPANIES, INC., A/K/A MARSHALS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PINNACLE HEALTH SYSTEM HARRISBURG HOSPITAL - RADIOLOGY DEPT. TO: 111 S. FRONT ST. HARRISBURG PA 17101 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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 seer m advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the doc mwats 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: MARK A. LOCKETT, ESQ. NAME' _ ADDRESS: TELEPHONE: FOR INFORMATION: (215) SUPREME COURT ID # ATTORNEY FOR: VEFEMANT Date: 5/,/12 Seat of Court ISSUED ON: 6/04/12 241-5858 ADDENDUM TO SUBPOENA 05042018 NO. 10-398 CIVIL 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A lu1P,RSHALLS ANY AND ALL DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/ JUREGARDING NE DRIVE, CAMPL ILL, CORRESPONDING REPORTS CROLG LAND ANNDC/ARROLESHIRVINSKY REPORTS PLETCHER NEE: A PA, DOB 04/17/52, SSN XXX-XX-1263) 05042014 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER VS. PLAINTIFF/S THE TJX COMPANIES, INC., A/K/A MARSHALLS DEFENDANT/S ?jq r5. } 1 IQ: COURT OF COMMON PLEAS SYLV, COUNT T NO. 10-398 CIVIL 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, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 6/04/12 A. LOCKETT, ESQ. NEY FOR DEFENDANT .6 N 05042014 12/25/12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas 10-398 CIVIL Vs. THE TJX COMPANIES, INC., A/K/A MARSHALLS File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PINNACLE HEALTH SYSTEM HARRISBURG HOSPITAL TO: 111 S. FRONT ST. HARRISBURG PA 17101 (Name of Person or Evtity) Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (Address) You may deliver or mail kgible 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 addrrss listed above. You have the right t0 seek in advance the reasonable cost of preparing the copies or producing the things sought If you fail to prodwe 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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) SUPREME COURT 9 -- ATT'ORNEY FOR. Date: a alOL S I of the Court ISSUED ON:. 6/04/12 241-5858 BY =Y-61P onotary, Civil Division Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 05042014 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS, WHATSOEVER REGARDING PLAINTIFF CARROL A. PLETCHER NEE: CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 04/17/52, SSN XXX-XX-1263) DEFENDANT/S COURT OF COMMON PLEAS NO. 10-398 CIVIL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 py o - /? (d 05112021 e?. COU, i 4t',_etIr i#?rh AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT CERTIFIES THAT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER VS. PLAINTIFF/S THE TJX COMPANIES, INC., A/K/A MARSHALLS (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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 6/11/12 t KEVIN E. MONASTRA, ESQ. A ORNEY FOR DEFENDANT JUN 12 2012 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas Vs. 10-398 CIVIL THE TJX COMPANIES, INC., A/K/A MARSHALLS File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 RHOADS & SINON LLP ONE S. MARKET ST. TO:S-12TH FLOOR HARRISBURG PA 17108 05112021iC LSO 12/25/12 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., 5-300, PHILADELPHIA, PA. at (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: KEVIN E. MONASTRA, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT j9A .,.,. ATTORNEY FOR Date: S 1 I Seal of the Court ISSUED ON 6/11/12 BY THE COURT: Prothonotary, Civil Division Depu JUN 1 2 2w w NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 05112021 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS PLAINTIFF'S CIVIL ACTION COMPLAINT, PLAINTIFF'S ANSWERS TO INTERROGATORIES, DOCUMENTS PRODUCED BY PLAINTIFF, PLAINTIFF'S DEPOSITION AND/OR TRIAL TESTIMONY AND ANY AND ALL PLEADINGS AND DISCOVERY WHATSOEVER REGARDING PRIOR ACTION BROUGHT BY PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, PA, DOB 4/17/52, SSN XXX-XX-1263) IN RE: CARROL PLETCHER V. SEARS ROEBUCK, CZAPP & GRIFFITH CO., AND COOL MASTER PROFESSIONAL SERVICES INVOLVING ASBESTOS HOME ABATEMENT. IN LIEU OF DOCUMENT PRODUCTION, KINDLY PRODUCE SIGNED AND NOTARIZED NO RECORDS STATEMENTS. i CARROL PLETCHER Vs. THE TJX COMPANIES, INC., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . File No. A/K/A MARSHALLS Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 .N 05112021 12/25/12 COMP "ERVICES 2505 N. FRONT ST. TO: HARRISBURG PA 17110 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. at (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 malting 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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR. Dhkh1q1)ANT Date: hr.? ,Seal of the Court ISSUED ON 6/11/12 BY THE COURT: ut& (- Prothonotary, Civil Division Depu NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 05112021 12/25/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSING RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS /CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, ASSISTED LIVING RECORDS, AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, PA, DOB 4/17/52, SSN XXX-XX-1263) ?l COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER PLAINTIFF/S vs. THE TJX COMPANIES, INC., A/K/A MARSHALLS DEFENDANT/S COURT OF COMMON PLEAS NO. 10-398 CIVIL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 08012013 ?a. N -,. rri c 7 rrn 4 Cai co v.. AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 8/30/12 I ? ll"Z? KEVIN E. MONASTRA, ESQ. ATTORNEY FOR DEFENDANT N ngn,2n? 12/25/12. II COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Vs. THE TJX COMPANIES, INC., A/K/A MARSHALLS ileNo. Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 METZGER WICKERSHAM LAW OFFICES 3211 N. FRONT ST. TO: P.O. BOX 5300 HARRISBURG PA 17110 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the camficate of compliance, to the party malting 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 KEVIN E. MONASTRA, ESQ. : ADDRESS: TELEPHONE: FOR INFORMATION: SUPREME COURT ID # ATTORNEY FOR: DEFENDANT Date: J ' S of Court ISSUED ON: 8/30/12 BY THE CO Pro Division Deputy (215) 241-5858 I , . NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 08012013 9/11/12 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS PLAINTIFF'S CIVIL ACTION COMPLAINT, PLAINTIFF'S ANSWERS TO INTERROGATORIES DOCUMENTS PRODUCED BY PLAINTIFF, PLAINTIFF'S DEPOSITION AND/OR TRIAL TESTIMONY AND ANY AND ALL PLEADINGS AND DISCOVERY WHATSOEVER REGARDING PRIOR ACTION BROUGHT BY PLAINTIFF, CARROL A. PLETCHER, NEE: CARROL GERLAND AND CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, PA, DOB 4/17/52, SSN XXX-XX-1263) IN RE: MOTOR VEHICLE ACCIDENT THAT OCCURRED ON OR ABOUT 6/1/1998. 05303012 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER rri czr PLAINTIFF/S ) COURT OF COMMON PLEAS � ! (}�= VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ) NO. 10-398-CIVIL "� ? Ac: DEFENDANT/S ) 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, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 6/27/13 iEF-119 E. MONASTRA, ESQ. ATTORNEY FOR DEFENDANT 05303012 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PA BUREAU OF POLICE & SAFETY 70E CAPITAL EAST WING TO: HARRISBURG PA 17125 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. (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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: T?nR INFORMATION- (915) 241-5858 SUPREME COURT ID# ATTORNEY FOR. DEFENDANT BY THE COIJRT,;.,,, Prothonotary,Civil Division Date: -SeA ofthe Court Deputy ISSUED ON: 6/27/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05303012 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL RECORDS REGARDING A MVA/PEDESTRIAN, D/INCIDENT 1/17/12 BETWEEN FORSTER STREET AND HEALTH & WELFARE BUILDING, HARRISBURG, PA PERTAINING TO: CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 InME DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) 0960.126 05303012 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) PLAINTIFF/S ) COURT OF COMMON PLEAS VS. ) THE TJX COMPANIES, INC. , A/K/A MARSHALLS ) NO. 10-398-CIVIL DEFENDANT/S ) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JORDAN J. CUNNINGHAM, ESQ. CUNNINGHAM & CHERNICOFF P.C. 2320 N. 2ND ST. HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , PHILADELPHIA, PA 19103 . YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858) , AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. PA BUREAU OF POLICE & SAFETY DR. MICHAEL DAROWISH, M.D. PENN STATE HERSHEY BONE & JOINT INST. DR. MICHAEL DAROWISH, M.D. PENN STATE HERSHEY BONE & JOINT INST. ENCOMPASS INSURANCE CO. NATIONWIDE INSURANCE COMPANY DATE: 5/31/13 KEVIN E. MONASTRA, ESQ. BONNER, KIERNAN, TREBACH & CROCIATA TEN PENN CENTER 5-770 1801 MARKET ST. PHILADELPHIA PA 19103-1606 ATTORNEY(S) FOR DEFENDANT N r , 112/225/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF TO: 3025MMARKET SICHAEL S—A, PA STATE 1701HERSHEY BONE & JOINT INST. (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. (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 parry 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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: FAR INFORMATION-4915) 241-5858 SUPREME COURT ID# ATTORNEY FOR DEFENDANT BY THE CO Prothonotary,Civil Division Date: lot 'S f the Court Deputy ISSUED ON: 6/27/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05303012 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSING RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS, ASSISTED LIVING RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N '-- 112/225/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas Vs. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF .THE RECORDS OF DR. MICHAEL DAROWISH, M.D. PENN STATE HERSHEY BONE & JOINT INST. TO: _ 30 HOPE DR S-2400 HERSHEY PA 17033 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the Mowing documents or things: SEE ATTACHED ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION- X915) 241-5858 SUPREME COURT ID# ATTORNEY FOR DEFENDANT Y THE COURT:_ /? Prothonotary,Ci ' Division Date: r J Sedl offthe Court Deputy ISSUED ON: 6/27/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05303012 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSING RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS, ASSISTED LIVING RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) 05303012 12/25/13 ti COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL • File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 ENCOMPASS INSURANCE CO. ONE MERIDIAN BLVD. TO: WYOMISSING PA 19610 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (Address) You may deliver or mil legible copies of the documents or produce things requested by this subpoena,together with the certificate of compliance,to the party malting 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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR DEkENDAN! BY THE CO ii Prothonotary,Civil Division Date: oe S&I of the Court Deputy ISSUED ON: 6/27/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05303012 7/16/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ALL RECORDS, PHOTOGRAPHS, STATEMENTS, CORRESPONDENCE, LETTERS, PAPERS, DRAFTS, BOOKS, MEDICAL REPORTS, ACCIDENT REPORTS AND ANY AND ALL DOCUMENTS OF ANY KIND WHATSOEVER IN YOUR POSSESSION OR CONTROL CONTAINED IN YOUR CLAIM NO 20195283, PERTAINING TO ANY CLAIMS BY CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) AS A RESULT OF AN ACCIDENT ON 01/17/12 N 05303012 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas VS. 10-398-CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 NATIONWIDE INSURANCE COMPANY 2515 MARKET ST. TO: CAMP HILL PA 17011 (N=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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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; KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE- POR TaFORMATION--4-2-15) 241-5858 SUPREME COURT DI)# ATTORNEY FOR-. DEFENDANT Y THE COURT; Prothonotary,Civil Division Date: "leal A the Court Deputy' ISSUED ON: 6/27[13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05303012 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ALL RECORDS, PHOTOGRAPHS, STATEMENTS, CORRESPONDENCE, LETTERS, PAPERS, DRAFTS, BOOKS, MEDICAL REPORTS, ACCIDENT REPORTS AND ANY AND ALL DOCUMENTS OF ANY KIND WHATSOEVER IN YOUR POSSESSION OR CONTROL CONTAINED IN YOUR CLAIM NO 58-37-D-005974, PERTAINING TO ANY CLAIMS BY CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) AS A RESULT OF AN ACCIDENT ON 01/17/12 05293017 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) PLAINTIFF/S ) COURT OF COMMON PLEAS vs. ) ;' THE TJX COMPANIES, INC. , A/K/A MARSHALLS ) NO. 10-398-CIVZ�:K DEFENDANT/S C5 C-� - G:; c= CERTIFICATE ' y." PREREQUISITE TO SERVICE OF A SUBPOENA N PURSUANT TO RULE 4009.22 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. n DATE: 7/01/13 MARK A. LO TT, ESQ. ATTORNEY FOR DEFENDANT 1VU. 1U-SytS-1 IV1L RIDER AULl'l'lUNAL LhYUNh1V'1'6 U56ySUl/ CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS PINNACLE HEALTH HOSPITAL AT POLYCLINIC RADIOLOGY DEPARTMENT, HARRISBURG, PA DR. ALBERT W. HECK, M.D. , LEMOYNE, PA CVS PHARMACY CORP. , WOONSOCKET, RI PINNACLE HEALTH SYSTEM HARRISBURG HOSPITAL - RADIOLOGY DEPT. , HARRISBURG, PA DR. WILLIAM A. ROLLE, JR. , M.D. PRISM, HARRISBURG, PA BECKER CHIROPRACTIC, LEMOYNE, PA CONFORTI PHYSICAL THERAPY & FITNESS CENTER, LEMOYNE, PA MAGNETIC IMAGING CENTER, MECHANICSBURG, PA PINNACLE HEALTH HOSPITAL, HARRISBURG, PA INTERNISTS OF CENTRAL PA, LEMOYNE, PA COMMONWEALTH OF PENNSYLVANIA BUREAU OF EMPLOYEE BENEFIT & SERVICES HARRISBURG, PA QUANTUM IMAGING & THERAPEUTIC ASSOC. , LEWISBERRY, PA RHOADS & SINON LLP, HARRISBURG, PA 0960 .126 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) ) PLAINTIFF/S ) COURT OF COMMON PLEAS VS. ) THE TJX COMPANIES, INC. , A/K/A MARSHALLS ) NO. 10-398-CIVIL DEFENDANT/S ) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JORDAN J. CUNNINGHAM, ESQ. CUNNINGHAM & CHERNICOFF P.C. 2320 N. 2ND ST. HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , PHILADELPHIA, PA 19103 . YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858) , AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. BECKER CHIROPRACTIC CAPITAL BLUE CROSS CONFORTI PHYSICAL THERAPY & FITNESS CENTER CVS PHARMACY CORP. DR. ALBERT W. HECK, M.D. HOLY SPIRIT HOSPITAL RITE AID OF PENNSYLVANIA INC. DR. WILLIAM A. ROLLE, JR. , M.D. PRISM COMMONWEALTH OF PENNSYLVANIA BUREAU OF EMPLOYEE BENEFIT & SERVICES MAGNETIC IMAGING CENTER HOLY SPIRIT HOSPITAL RADIOLOGY & DIAGNOSTIC IMAGING QUANTUM IMAGING & THERAPEUTIC ASSOC. MILTON S. HERSHEY MEDICAL CENTER KUNKEL SURGICAL GROUP ... SEE RIDER FOR ADDITIONAL DEPONENTS DATE: 5/30/13 MARK A. LOCKETT, ESQ. BONNER, KIERNAN, TREBACH & CROCIATA TEN PENN CENTER 5-770 1801 MARKET ST. PHILADELPHIA PA 19103-1606 ATTORNEY(S) FOR DEFENDANT NO. 10-398-CIVIL RIDER ADDITIONAL DEPONENTS 05293017 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS PINNACLE HEALTH HOSPITAL INTERNISTS OF CENTRAL PA PINNACLE HEALTH HOSPITAL AT POLYCLINIC RADIOLOGY DEPARTMENT PINNACLE HEALTH SYSTEM HARRISBURG HOSPITAL PINNACLE HEALTH SYSTEM HARRISBURG HOSPITAL - RADIOLOGY DEPT. RHOADS & SINON LLP PENNSYLVANIA EMPLOYEES BENEFIT TRUST FUND N _ 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas VS. 10-398—CIVIL THE TJX COMPANIES, INC. , A/K/A MARSHALLS; File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF BECKER CHIROPRACTIC 501 MARKET ST. TO: LEMOYNE PA 17043 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: 3�� ,��1,F e IProthonotary,Civil Division Date: � �. � /'1��/li �— -Seal of the Court Deputy ISSUED ON: 7/1/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 10/01/11 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CAPITAL BLUE CROSS 2500 ELMERTON AVE. TO: HARRISBURG PA 17177 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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 malting 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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR DEITNOANf BY THE COUR 1U-1 . ✓ Prothonotary,Civil Di-sio n Date: 'Seal f Court C, Deputy ISSUED ON: 7-1-13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A KARSHALLS SEE ATTACHED ADDENDUM PERTAINING TO CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) . s - ,r ***RECORDS FROM 10/01/11 TO THE PRESENT ONLY*** S�P-ECIAI,INSTRUCTIONS: INSURANCE RECORDS-Capital Blue Cross/Blue Shield Any and all insurance records,including but not limited to medical records,policy information, underwriting files, claims files, claims notes,claims investigations,surveillance,statements,legal proceedings,declaration pages, tort sections,tort options,correspondence,handwritten notes, and any and all insurance records whatsoever regarding plaintiff, Carrol A.Pletcher,(nee: Carrol Gerland; and,Carrol Shirvinsky); Date of Birth 4/17/1952; SS##183-42-1263; Group#PIT361.; ID#PFP89043347.400. a e 05293017 12/25/13 i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398—CIVIL THE TJX COMPANIES, INC. , A/K/A MARSHALLS, File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN. OF THE RECORDS OF CONFORTI PHYSICAL THERAPY & FITNESS CENTER TO: 110 N. 7TH ST. LEMOYNE PA 17043 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT IDE ATTORNEY FOR BY THE COURT �/G 2 a Prothonotary,Civil Division Date: 'e Seal cif thi Court C, Deputy ISSUED ON: 7/1/13 9 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 10/01/11 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CVS PHARMACY CORP.' ONE CVS DR. TO: WOONSOCKET RI 02895 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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 m 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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR DEkENDANT BY THE CO T- Prothonotary,Civil Division Date: -Seal ot the Court ISSUED ON: 7/1/13 S � i NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS SEE ATTACHED ADDENDUM PERTAINING TO CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) PRESCRIPTIONS FILLED @ CVS PHARMACY, 3201 MARKET ST. , CAMP HILL, PA. i 1 ' ***RECORDS FROM 10/01/11 TO THE PRESENT ONLY*** SPECIAL INSTRUCTIONS• PRARMACY RECORDS-CYS Pharmacvt and,Rite Aid Pharmaa Any and all pharmacy records including prescription games, prescription receipts, prescription billing records, frequency,milligrams, etc.,and any and all pharmacy records whatsoever regarding plaintiff,Carrol A.Pletcher, (nee; Carrol Gerland; and, Carrol Shirvinsky)g Date of Birth 4/17/1952; SS 9183-42-1263. N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF DR. ALBERT W. HECK, M.D. 110 LOWTHER ST. TO: LEMOYNE PA 17043 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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 Tl1E REQUEST OF THE FOLLOWING PERSON: NAME: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR: DEkENDANf BY THE COURT: A Prothonotary, Divis� OD ion Date: I -,e 'Seat of'he Court Deputy ISSUED ON: 7/1/13 { NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 10/01/11 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) BXN 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398-CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS I FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HOLY SPIRIT HOSPITAL 503 N. 21ST ST. TO: CAMP HILL PA 17011-2288 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE:— Fog TNFoRmATToN: 15) 241-5858 SUPREME COURT DD# ATTORNEY FOR. DEFENDANI BY THE COURT: I % i- 7 D, Prothonotary, i - 'Zi n Date-, -Sw� Seal of the Cburt C Deputy ISSUED ON: 7/1/13 } 4 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 10/01/11 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) S N �. 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas Vs. 10-398—CIVIL THE TJX COMPANIES, INC. , A/K/A MARSHALLS ; File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 RITE AID OF PENNSYLVANIA INC. P.O. BOX 3165 TO: HARRISBURG PA 17105-3165 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR D E BY THE COURT: Q Prothonotary,Civil Division Date: J 'Seal o the Court Deputy ISSUED. ON: 7/1/13 a .s NO. 10-398—CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS SEE ATTACHED ADDENDUM PERTAINING TO CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX—XX-1263) PRESCRIPTIONS FILLED Q 1137 MARKET ST. , LEMOYNE, PA 17043 ***RECORDS FROM 10/01/11 TO THE PRESENT ONLY*** SPECIAL INSTRUCTIONS: PIKARMACY RECORDS--- CY Pharma ,, and Rite Aid Pharmacy Any and all pharmacy records including prescription games, prescription receipts, prescription billing records, frequency,milligrams, etc.,and any and all pharmacy records Whatsoever regarding plaintiff,Carrol A.Pletcher, (nee: Carrot Gerland; and, Carrol Shirvinsky); Date of Birth 4/17/1952; SS 9183-42-1263. N 05293017 i_ 12/25/13 t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS . SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400912 CUSTODIAN OF THE RECORDS OF DR. WILLIAM A. ROLLE, JR. , M.D. PRISM TO: 4310 LONDONDERRY RD. S-106 BLOOM BUILDING HARRISBURG FA I/iU9 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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 malting 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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ED# ATTORNEY FOR: DEPENDANT BY THE COURT: ( n 2 2 othonotary, Civil Division Date: VL J ( ✓ 'Sea]of the dourt Deputy ISSUED ON: 7/1/13 ,r NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 10/01/11 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES', BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS . SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PERSONNEL DEPARTMENT COMMONWEALTH OF PENNSYLVANIA BUREAU OF EMPLOYEE BENEFIT & 'SERVICES TO: DEPARTMENT OF HEALTH 625 FORSTER ST., ROOM 126 HARRISBURG FA I/IZU":Weof 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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR: DE DANT BY THE COURT,-, lst4 '00t fop Protho notary,Civil D ion Date: -S&O of ddCourt Deputy ISSUED ON: 7/1/13 I NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS EMPLOYMENT/DISABILITY RECORDS FROM 12/01/11 TO THE PRESENT ONLY REGARDING PLAINTIFF CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROLL SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) PERSONNEL NUMBER: 515848 N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS .FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF MAGNETIC IMAGING CENTER 4665 TRINDLE RD. TO: MECHANICSBURG PA 17050 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (2 5) 241-5858 SUPREME COURT ID# ATTORNEY FOR. DEFENDANT BY THE COURT: aw - ► ,.p Date. Prothonotary,Civil Division A24,C �—? - Seal f th Court Deputy ISSUED ON: 7/1/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL DIAGNOSTIC MRI, X-RAY FILMS OR, SCANS ALONG WITH ACCOMPANYING DIAGNOSTIC REPORTS FROM 12/01/11 TO THE PRESENT ONLY REGARDING PLAINTIFF CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) N 2/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas Vs. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS . SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT HOLY SPIRIT HOSPITAL RADIOLOGY & DIAGNOSTIC IMAGING TO: 503 N. 21ST ST. CAMP HILL PA 17011 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: Prothonotary, Civil Division Date: 'Seal of the ourt Deputy ISSUED ON: 7/1/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL DIAGNOSTIC MRI, X-RAY FILMS OR SCANS ALONG WITH ACCOMPANYING DIAGNOSTIC REPORTS FROM 12/01/11 TO THE PRESENT ONLY REGARDING PLAINTIFF CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) PATIENT SEEN @ QUANTUM IMAGING AND THERAPEUTIC ASSOC. , 405 ST. JOHN'S CHURCH ROAD, 5-102, CAMP HILL, PA. N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS , SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF QUANTUM IMAGING & THERAPEUTIC ASSOC. 629D LOWTHER RD. TO: EWISBERRY PA 17339 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (Address) 'bit copies of the documents or produce things requested by this You may deliver or mail legible cc thin 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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT J)# ATTORNEY FOR: DErENIjPU!17T BY THE COURT: �13 Prothonotary,Civil Division Date: �� •Seal a€the Court �Deputy ISSUED ON: 7/1/13 ar NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL DIAGNOSTIC MRI, X-RAY FILMS OR SCANS ALONG WITH ACCOMPANYING REPORTS FROM 12/01/11 TO THE PRESENT ONLY REGARDING PLAINTIFF CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) SBXN 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas VS. 10-398—CIVIL THE TJX COMPANIES, INC., A/K/A MARSHALLS File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT MILTON S. HERSHEY MEDICAL CENTER 500 UNIVERSITY DR. TO: P.O. BOX 850 HERSHEY PA 17033 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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 malting 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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE:— FOR INFORMATION: 241-5858 SUPREME COURT ID# ATTORNEY FOR. Dh1,hNJJANi BY THE COURT: 311S Civil Division Date: Seal of the Court Deputy ISSUED ON: 7/1/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 01/01/12 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF KUNKEL SURGICAL GROUP 890 POPLAR CHURCH RD. S-210 TO: CAMP HILL PA 17011 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT 1D# ATTORNEY FOR: D E BY THE COURTi_ Prothonotary,Civil Division Date: 3113 'Seal o the Court Deputy ISSUED ON: 7/1/13 v NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 01/01/12 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N 05293017 ` — 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398—CIVIL THE TJX COMPANIES, INC. , A/K/A MARSHALLS File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PINNACLE HEALTH HOSPITAL 409 S. 2ND ST. TO: HARRISBURG PA 17104 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME FENDANT ATTORNEY FOR BY THE COURT: Prothonotary,Civil D'- ion A0 Date: J C S of Court Deputy ISSUED ON: 7/1/13 l NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 01/01/12 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N 05293017 i 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398—CIVIL THE TJX COMPANIES, INC. , A/K/A MARSHALLS: File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF INTERNISTS OF CENTRAL PA 108 LOWTHER ST. TO: LEMOYNE PA 17043 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: NAMEMARK A. LOCKETT, ESQ. : ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT]� ATTORNEY FOR BY THE CO T: Prothonotary, Civil Dixision Date: � J S of Court Deputy ISSUED ON: 7/1/13 1 i J NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 04/01/12 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) INCLUDING RECORDS FROM MICHAEL L. GLUCK, M.D. AND PATRICK RATNASAMY, MD. N 05293017 12/25/13 .l COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PINNACLE HEALTH HOSPITAL AT POLYCLINIC RADIOLOGY DEPARTMENT TO: 2501 N. THIRD ST. HARRISBURG PA 17110 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR: DEFENDANI BY THE COURT \u �} 2 Prothonotaryv ,Civil Division Date: V! � I J , 'Seal of the Court Deputy ISSUED ON: 7/1/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL FILMS AND REPORTS FROM 4/1/12 TO THE PRESENT ONLY REGARDING CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) B N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PINNACLE HEALTH SYSTEM HARRISBURG HOSPITAL TO: 111 S FRONT ST HARRISBURG PA 17101 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: 2 Prothonotary,Civil Division Date: -Seal bf Court Deputy ISSUED ON: 7/1/13 ,- NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 05/01/12 TO PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX-XX-1263) N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas VS. 10-398—CIVIL : THE TJX COMPANIES, INC., A/K/A MARSHALLS . File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PINNACLE HEALTH SYSTEM HARRISBURG HOSPITAL — RADIOLOGY DEPT. TO: III S. FRONT ST. HARRISBURG PA 17101 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREMY,COURT ID# ATTORNEY FOR DE BY THE-COURT: Prothonotary,Civil D ion Date: tp 13112 .0 'Seal of Court Deputy ISSUED ON: 7t1/13 NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER . VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL DIAGNOSTIC STUDIES X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS AND CT SCANS/CORRESPONDING REPORTS FROM 5/01/12 TO THE PRESENT ONLY REGARDING CARROL A. PLETCHER (NEE: CARROL GERLAND AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) _ N 05293017 12/25/13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER • Court of Common Pleas Vs. 10-398-CIVIL THE TJX COMPANIES, INC. , A/K/A MARSHALLS File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 RHOADS & SINON LLP C/O STEPHANIE DI VITTORE TO: ONE S. MARKET ST. S-12TH FLOOR HAKRISBUKU FA I/= (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215)241-5858 SUPREME COURT ENDANT ATTORNEY FOR: BY THE COURT. � .� .le'LL 3 Prothonotary, Civil Division Date: l 'Seal of the Court Deputy ISSUED ON: 7/1/13 a� 40. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TJX COMPANIES, INC. , A/K/A MARSHALLS RECORDS FROM 5/01/12 TO THE PRESENT ONLY REGARDING PLAINTIFF'S CIVIL ACTION COMPLAINT, PLAINTIFF'S ANSWERS TO INTERROGATORIES, DOCUMENTS PRODUCED BY PLAINTIFF, PLAINTIFF'S DEPOSITION AND/OR TRIAL TESTIMONY AND ANY AND ALL PLEADINGS AND DISCOVERY WHATSOEVER REGARDING PRIOR ACTION BROUGHT BY PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND; AND CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) IN RE: CARROL PLETCHER V. SEARS ROEBUCK, CZAPP & GRIFFITH CO. , AND COOL MASTER PROFESSIONAL SERVICES INVOLVING ASBESTOS HOME ABATEMENT. IN LIEU OF DOCUMENT PRODUCTION, KINDLY PRODUCE SIGNED AND NOTARIZED NO RECORDS STATEMENT. N 05293017 12/25/13 A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER Court of Common Pleas Vs. 10-398—CIVIL File No. THE TJX COMPANIES, INC. , A/K/A MARSHALLS. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PENNSYLVANIA EMPLOYEES BENEFIT TRUST FUND TO: 150 S. 443RD ST. S-1 HARRISBURG PA 17111-5700 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD. , S-300, PHILADELPHIA, PA. at (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 FOLLOWNG PERSON: NAME: MARK A. LOCKETT, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID# ATTORNEY FOR: D E BY THE COURT: 2 Prothonotary,Civil ivisioni Date: JCL�1�- -seai of a Court - t3 ISSUED ON: 7/1/13 t �r r • NO. 10-398-CIVIL ADDENDUM TO SUBPOENA 05293017 12/25/13 CARROL PLETCHER VS. THE TUX COMPANIES, INC. , A/K/A MARSHALLS ANY AND ALL HEALTH CARE BENEFITS, MEDICAL AND/OR BILLING RECORDS FROM 11/01/12 TO THE PRESENT ONLY REGARDING MEDICAL LIEN INVOLVING CARROL PLETCHER/GERLAND/SHIRVINSKY (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 4/17/52, SSN XXX-XX-1263) 02214031 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) PLAINTIFF /S ) COURT OF COMMON PLEAS C �►- VS. ) • `p3 2-• -f THE TJX COMPANIES, INC., A /K /A MARSHALLS ) NO. 10- 398 -CIVIL or- DEFENDANT /S ) ? C, �-t • rJ 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, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 3/31/14 KEVIN E. MONASTRA, ESQ. ATTORNEY FOR DEFENDANT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER vs. File No. THE TJX COMPANIES, INC., A /K /A MARSHALLS Court of Common Pleas 10- 398 —CIVIL N 02214031 12/25/14 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF TO: iONFORTI PHYSICALTHEERAPY & 70I FTNESS CENTER (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 ADDENDUM atRECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S -300, PHILADELPHIA, PA. (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: KEVIN E. MONASTRA, ESQ: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241 -5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT Date: )141 'Seal of the Court ISSUED ON: 3/31/14 BY THE COURT: Prothonotary, mil Division Deputy Deoury D NO. 10- 398 -CIVIL ADDENDUM TO SUBPOENA 02214031 12/25/14 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A /K /A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 5/1/13 TO THE PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND- WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT- PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X- RAYS /CORRESPONDING REPORTS, MRI'S /CORRESPONDING REPORTS, CT SCANS /CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX -XX -1263) COMMONWEALTH OF PENNSYLVANIA COTJNTY OF OTJMBEB T AND CARROL PLETCHER vs. File No. THE TJX COMPANIES, INC., A /K /A MARSHALLS Court of Common Pleas 10- 398 -CIVIL N 02214031 12/25/14 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF TO: DR.SMrICHAEL DAROWISH ,rM.D.H PENN pSSTATE tHERSHEY BONE & JOINT INST. (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 ADDENDUM REaORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S -300, PHILADELPHIA, PA. (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 : KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONECOURT : FOR ID # INFORMATION: (215) 241 -5858 SUPREME ATTORNEY FOR.: DEFENDANT Date: )?-) h 'Seal of the Court Deputy BY THE COURT: .I Prothonotary, Civil Division ISSUED ON: 3/31/14 NO. 10- 398 -CIVIL ADDENDUM TO SUBPOENA 02214031 12/25/14 CARROL PLETCHER VS. THE TJX COMPANIES, INC . , A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 5/1/13 TO THE PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND- WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT- PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSING RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X- RAYS /CORRESPONDING REPORTS, MRI'S /CORRESPONDING REPORTS, CT SCANS /CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS, ASSISTED LIVING RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX -XX -1263) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CJ_MBFRLA.ND CARROL PLETCHER vs. File No. THE TJX COMPANIES, INC., A /K /A MARSHALLS Court of Common Pleas 10- 398 -CIVIL N 02214031 12/25/14 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF INTERNISTS OF CENTRAL PA 108 LOWTHER ST. TO: LEMOYNE PA 17043 (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 ADDENDUM aFECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S -300, PHILADELPHIA, PA. (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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241 -5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT Date: � p—% 'Seal of the Court Deputy BY THE COURT: Prothonotary, Civil Division ISSUED ON: 3/31/14 NO. 10- 398 -CIVIL ADDENDUM TO SUBPOENA 02214031 12/25/14 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A /K /A MAR.SHALLS ANY AND ALL UPDATED MEDICAL-RECORDS FROM 5/1/13 TO THE PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND- WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT- PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X- RAYS /CORRESPONDING REPORTS, MRI'S /CORRESPONDING REPORTS, CT SCANS /CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX -XX -1263) I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUTABERLAND CARROL PLETCHER vs. File No. THE TJX COMPANIES, INC., A /K /A MARSHALLS Court of Common Pleas 10- 398 -CIVIL SBXN 02214031 12/25/14 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MEDICAL RECORDS DEPARTMENT PENN STATE MILTON S. HERSHEY MEDICAL CTR 500 UNIVERSITY DR. TO: P.O. BOX 850 HERSHEY PA 17033 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S -300, PHILADELPHIA, PA. (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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241 -5858 SUPREME COURT ID # ATTORNEY FOR DEFENDANT Date: -aldr? Seal of the Court ISSUED ON: 3/31/14 BY THE COURT: Prothonotary, Civil Division NO. 10- 398 -CIVIL ADDENDUM TO SUBPOENA 02214031 12/25/14 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL UPDATED MEDICAL RECORDS FROM 5/1/13 TO THE PRESENT, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND- WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS RECORDS, IN- PATIENT RECORDS, OUT - PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTIC STUDIES, X- RAYS /CORRESPONDING REPORTS, MRI'S /CORRESPONDING REPORTS, CT SCANS /CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX -XX -1263) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) ) ) PLAINTIFF/S ) VS. ) ) THE TJX COMPANIES, INC., A/K/A MARSHALLS ) NO. 10-398 CIVIL COURT OF COMMON PLEAS ) ) DEFENDANT/S ) CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 02214003 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 3/31/14 L KEVIN E. MONASTRA, ESQ. ATTORNEY FOR DEFENDANT 0960.126 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) PLAINTIFF /S ) COURT OF COMMON PLEAS VS. ) 1 THE TJX COMPANIES, INC., A /K /A MARSHALLS ) NO. 10 -398 CIVIL } DEFENDANT /S NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JORDAN J. CUNNINGHAM, ESQ. CUNNINGHAM & CHERNICOFF P.C. 2320 N. 2ND ST. HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 02214003 12/25/14 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT /S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215- 241 - 5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA /S MAY BE SERVED. NATIONWIDE INSURANCE COMPANY DATE: 2/24/14 KEVIN E. MONASTRA, ESQ. BONNER, KIERNAN, TREBACH & CROCIATA TEN PENN CENTER S -770 1801 MARKET ST. PHILADELPHIA PA 19103 -1606 ATTORNEY(S) FOR DEFENDANT 02214003 12/25/14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER vs. THE TJX COMPANIES, INC., A /K /A MARSHALLS: Court of Common Pleas 10 -398 CIVIL File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 NATIONWIDE INSURANCE COMPANY P.O. BOX 2655 TO: HARRISBURG PA 17105 (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 ADDENDUM RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S -300, PHILADELPHIA, PA. (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: KEVIN E. MONASTRA, ESQ. ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241 -5858 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT Date: 'Seal of the Court ISSUED ON: 3/31/14 BY THE COURT: Prothonotary, Civil Division NO. 10 -398 CIVIL ADDENDUM TO SUBPOENA 02214003 12/25/14 CARROL PLETCHER VS. THE TJX COMPANIES, INC., A /K /A MARSHALLS ANY AND ALL UPDATED RECORDS FROM 5/1/13 TO THE PRESENT ONLY, INCLUDING BUT NOT LIMITED TO MEDICAL RECORDS, POLICY INFORMATION, UNDERWRITING FILES, CLAIMS FILES, CLAIMS NOTES, CLAIMS INVESTIGATIONS, SURVEILLANCE, STATEMENTS, LEGAL PROCEEDINGS, DECLARATION PAGES, TORT SECTIONS, TORT OPTIONS, COMMUNICATION, .HANDWRITTEN NOTES, WORKER'S COMPENSATION RECORDS AND ANY AND ALL INSURANCE RECORDS WHATSOEVER REGARDING PLAINTIFF CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX- XX- 1263), FOR INCIDENT DATED 1/17/12, CLAIM #58 -37 -D- 005974; INSURANCE AGENT: CAROL UMBRELLE. 0960.126 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) ) PLAINTIFF /S ) VS. ) THE TJX COMPANIES, INC., A /K /A MARSHALLS ) NO. 10- 398 -CIVIL COURT OF COMMON PLEAS ) DEFENDANT /S ) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JORDAN J. CUNNINGHAM, ESQ. CUNNINGHAM & CHERNICOFF P.C. 2320 N. 2ND ST. HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 02214031 12/25/14 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT /S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215 - 241 - 5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA /S MAY BE SERVED. CONFORTI PHYSICAL THERAPY & FITNESS CENTER DR. MICHAEL DAROWISH, M.D. PENN STATE HERSHEY BONE & JOINT INST. INTERNISTS OF CENTRAL PA PENN STATE MILTON S. HERSHEY MEDICAL CTR DATE: 2/24/14 KEVIN E. MONASTRA, ESQ. BONNER, KIERNAN, TREBACH & CROCIATA TEN PENN CENTER S -770 1801 MARKET ST. PHILADELPHIA PA 19103 -1606 ATTORNEY(S) FOR DEFENDANT BONNER KIERNAN TREBACH & CROCIATA, LLP BY: MARK A. LOCKETT, ESQUIRE IDENTIFICATION NO: 50023 TEN PENN CENTER, SUITE 770 1801 MARKET STREET PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEY FOR DEFENDANT, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls) CARROL PLETCHER v. THE TJX COMPANIES, INC. a/k/a MARSHALLS Plaintiff Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-398 CIVIL DEMAND FOR JURY TRIAL TO THE PROTHONOTARY: A jury trial is hereby demanded in the above -entitled action. BONNER KIERNAN REBACH & C ;o CIATA, LLP LO ' TT, ESQUIRE Attorne; for, iendant, Marm : xx Operating Corp. (improperly desig ated as The TJX Companies, Inc.) BONNER KIERNAN TREBACH & CROCIATA, LLP BY: MARK A. LOCKETT, ESQUIRE IDENTIFICATION NO: 50023 TEN PENN CENTER, SUITE 770 1801 MARKET STREET PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEY FOR DEFENDANT, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls) CARROL PLETCHER v. THE TJX COMPANIES, INC. a/k/a MARSHALLS Ftdlii�i_t. . Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-398 CIVIL CERTIFICATE OF SERVICE I, Mark A. Lockett, Esquire, hereby certify that on the 3rd day of November, 2014, a true and correct copy of the attached Demand for Jury Trial, was served via U.S. Mail, First Class, Postage Prepaid, upon the following: Jordan J. Cunningham, Esquire Cunningham & Chernicoff, P.C. 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 BONNEKI' RNAN T' . A CROCIATA,.LLP MAW A. LO ' T, ' SQUIRE Attorney for I efendant, M. maxx '.perating Corp. (improperly de.ignated as The TJX Companies, Inc.) PRAECIPE FOR LISTING CASE FOR JURY TRIAL 261_; t1` � IG (Must be typewritten and submitted in triplicate) PEN TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case for a Jury Trial. 0 12 PH 1:53 CO 1/4 PtI CARROL PLETCHER (Plaintiff) vs. THE TJX COMPANIES INC. a/k/a MARSHALLS (check one) x Civil Action — Law Appeal from arbitration (other) No. 10-398 Civil Term The trial list will be called on 2/24/15 and (Defendant) Pretrials will be held on 3/11/15 vs. (Briefs are due 5 days before pretrials) Trials commence on 3/23/15 Indicate the attorney who will try case for the party who files this praecipe: MARK A. LOCKETT, ESQUIRE, BONNER KIERNAN, 1801 Market St, Ste 770, Phila.,PA Indicate trial counsel for other parties if known: Jordan J. Cunningham, Esquire CUNNINGHAM & CHERNICOFF, P.C. 2320 N. SECOND STREET Harrisburg, PA 17106 (717-238-6570) This case is ready for trial. Date: November 10, 2014 (Counsel for Plaintiff) Signed: Print Name: ARK A. LOCKETT Attorney for: Defendant OLuk sYcmA% ami �# 31331 BONNER KIERNAN TREBACH & CROCIATA, LLP BY: MARK A. LOCKETT, ESQUIRE IDENTIFICATION NO: 50023 TEN PENN CENTER, SUITE 770 1801 MARKET STREET PHILADELPHIA, PA 19103 (215) 569-4433 ATTORNEY FOR DEFENDANT, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc. a/k/a Marshalls) CARROL PLETCHER V. THE TJX COMPANIES, INC. a/k/a MARSHALLS Plaintiff Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 10-398 CIVIL CERTIFICATE OF SERVICE I, Mark A. Lockett, Esquire, hereby certify that on the 10th day of November, 2014, a true and correct copy of the attached Praecipe for Listing Case for Jury Trial, was served via U.S. Mail, First Class, Postage Prepaid, upon the following: Jordan J. Cunningham, Esquire Cunningham & Chernicoff, P.C. 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 BONNER KIERNAN TREBACH & CROCIATA, LLP BY: MARK A. LO KET , ESQ Attorney for P efendant, Marmaxx Operating Corp. (improperly designated as The TJX Companies, Inc.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) ) PLAINTIFF/S ) COURT OF COMMON PLEAS VS. ) THE TXJ COMPANIES, INC., A/K/A MARSHALLS ) NO. 10-398 CIVIL DEFENDANT/S ) CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 10224006 AS A PREREQUISITE TO SERVICE OF A SUBPOENA FOR DOCUMENTS AND THINGS PURSUANT TO RULE 4009.22, DEFENDANT 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 THAT WILL BE SERVED IS IDENTICAL TO THE SUBPOENA WHICH IS ATTACHED TO THE NOTICE OF INTENT TO SERVE THE SUBPOENA. DATE: 11/21/14 KEVIN E. MONASTRA, ESQ. ATTORNEY FOR DEFENDANT 0960.126 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER ) PLAINTIFF/S ) COURT OF COMMON PLEAS VS. ) THE TXJ COMPANIES, INC., A/K/A MARSHALLS ) NO. 10-398 CIVIL DEFENDANT/S ) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JORDAN J. CUNNINGHAM, ESQ. CUNNINGHAM & CHERNICOFF P.C. 2320 N. 2ND ST. HARRISBURG PA 17110 ATTORNEY(S) FOR PLAINTIFF 10224006 12/25/14 DEFENDANT INTENDS TO SERVE A SUBPOENA IDENTICAL TO THE ONE THAT IS ATTACHED TO THIS NOTICE TO THE DEPONENT/S LISTED BELOW, REQUESTING RECORDS BE PRODUCED AT RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., PHILADELPHIA, PA 19103. YOU HAVE TWENTY (20) DAYS FROM THE DATE LISTED BELOW IN WHICH TO FILE OF RECORD AND SERVE UPON THE UNDERSIGNED AND RECORD COPY SERVICES (215-241-5858), AN OBJECTION TO THE SUBPOENA. IF NO OBJECTION IS MADE THE SUBPOENA/S MAY BE SERVED. DR. WILLIAM J. BEUTLER, M.D. JOHN RAMIREZ, PH.D. DATE: 10/23/14 KEVIN E. MONASTRA, ESQ. BONNER, KIERNAN, TREBACH & CROCIATA TEN PENN CENTER S-770 1801 MARKET ST. PHILADELPHIA PA 19103-1606 ATTORNEY(S) FOR DEFENDANT •d, N 10224006 12/25/14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER vs. THE TXJ COMPANIES, INC., A/K/A TO: • File No. Court of Common Pleas 10-398 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009 22 CUSTODIAN OF THE RECORDS OF DR. WILLIAM J. BEUTLER, M.D. THE ARLINGTON GROUP 805 SIR THOMAS CT. HARRISBURG PA 17109 (Maine 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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. (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 nipking 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: KEVIN E. MONASTRA, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR: Date:D. ISSUED ON: 11/21/14 Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA 10224006 12/25/14 CARROL PLETCHER VS. THE TXJ COMPANIES, INC., A/K/A MARSHALLS ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES,_ MEMORANDA, PRESCRIPTIONS RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSING RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS, ASSISTED LIVING RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, PA, CUMBERLAND COUNTY, DOB 04/17/52, SSN XXX -XX -1263) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CARROL PLETCHER vs. THE TXJ COMPANIES , INC. , A/K/A MARSHALLS File N°. Court of Common Pleas 10-398 CIVIL N 10224006 12/25/14 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CUSTODIAN OF THE RECORDS OF JOHN RAMIREZ, PH.D. 4701 DEVONSHIRE RD. S-105 TO: HARRISBURG PA 17109 (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 ADDENDUM at RECORD COPY SERVICES, 1880 JOHN F. KENNEDY BLVD., S-300, PHILADELPHIA, PA. • (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: KEVIN E. MONASTRA, ESQ. NAME: ADDRESS: TELEPHONE: FOR INFORMATION: (215) 241-5858 SUPREME COURT ID # ATTORNEY FOR.: Date: ISSUED ON: 11/21/14 Deputy NO. 10-398 CIVIL ADDENDUM TO SUBPOENA CARROL PLETCHER VS. THE TXJ COMPANIES, INC., A/K/A MARSHALLS 10224006 12/25/14 ANY AND ALL MEDICAL RECORDS, INCLUDING BUT NOT LIMITED TO MEDICAL REPORTS, PROGRESS NOTES, HAND-WRITTEN NOTES, MEMORANDA, PRESCRIPTIONS.RECORDS, IN-PATIENT RECORDS, OUT-PATIENT RECORDS, EMERGENCY ROOM RECORDS, TRIAGE RECORDS, DISCHARGE INSTRUCTIONS, EMERGENCY OR RESCUE RECORDS, NURSING RECORDS, NURSE'S NOTES, BILLING RECORDS, LAB STUDIES, TEST RESULTS, DIAGNOSTICS STUDIES, X-RAYS/CORRESPONDING REPORTS, MRI'S/CORRESPONDING REPORTS, CT SCANS/CORRESPONDING REPORTS, PHYSICAL THERAPY RECORDS, CHIROPRACTIC THERAPY RECORDS, OCCUPATIONAL THERAPY RECORDS, REHABILITATION RECORDS, ASSISTED LIVING RECORDS AND ANY AND ALL RECORDS WHATSOEVER REGARDING PLAINTIFF, CARROL A. PLETCHER (NEE: CARROL GERLAND; AND, CARROL SHIRVINSKY) (103 JUNE DRIVE, CAMP HILL, CUMBERLAND COUNTY, PA, DOB 04/17/52, SSN XXX -XX -1263)