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HomeMy WebLinkAbout10-0959IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) & Address(es) MARY K. PRIMROSE 500 Geneva Dr., Apt. C4 Mechanicsburg, PA 17055 VS. Defendant(s) & Address(es) MAUREEN M. MINDER 422 Brian Court Mechanicsburg, PA 17050 CIVIL DIVISION Case No. h - 59 Civil Term Civil Action PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above case Ca Q, .?- ZS) 499 4 a .Writ of Summons shall be issued and forwarded to Attorne /Sheri le se ircle e Date : y ZO d Signature of Attorney Print Name: Dennis J. shatto C ec an Fearen Address: 119 IACust Street . Harrisburg, PA 17101 Telephone #: 717-238-1731 Supreme Court ID Number: 25675 TO: MAUREEN M. MINDER • • • • • WRIT OF SUMMONS YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HASMAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary/Clerk, Civil Division Date: by Ce_? eputy ??I' 06 04 Z#Y SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy xtr ?{ C11114t,"tt'114 F I Ir 2010 FEB 16 PH 2= 2 Edward L Schorpp Solicitor Mary K. Primrose VS. Maureen M. Minder OFD , -. "RIFF Case Number 2010-959 SHERIFF'S RETURN OF SERVICE 02/05/2010 02:25 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on February 5, 2010 at 1425 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Maureen M. Minder, by making known unto herself personally, at 422 Brian Court, 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 February 09, 2010 SO AN ERS Y R ANDERSON, SHERIFF By De ty heriff t in? Sot a?ri. rF on 1'-T. op FILED-riFFICE 2;1 J'-2 QPt 9: 351 CUMBERLAND CCUr'? T- ,r PENIgs yj VANIA MARY K. PRIMROSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 10-959 MAUREEN M. MINDER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A 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 AVISO USTED HA SIDO DEMANDADO/A EN COURTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6 de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualguier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABODAGO 1NMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 1701.3 1-800-990-9108 717-249-3166 Dennis J. Shatto, Esquire Pa. Supreme Court ID #25675 Cleckner and Fearen 119 Locust Street P. O. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 (Attorneys for Plaintiffi MARY K. PRIMROSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 10-959 MAUREEN M. MINDER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff is Mary K. Primrose, an adult individual who resides at 500 Geneva Drive, Apt. C4, Mechanicsburg, Pennsylvania, 17055. 2. Defendant is Maureen M. Minder, an adult individual who resides at 422 Brian Court, Mechanicsburg, Pennsylvania, 17050. 3. On February 21, 2008, at approximately 6:40 a.m., Plaintiff was driving a 1996 Honda Civic, in a northerly direction on Wesley Drive, at its intersection with Gettysburg Road, in Lower Allen Township, Cumberland County, Pennsylvania. 4. At the time and place aforesaid, Defendant was driving a 2008 Toyota Corolla in a southerly direction on Wesley Drive, approaching its intersection with Gettysburg Road. 5. As Plaintiff entered the intersection, intending to continue northbound on Wesley Drive, Defendant, approaching the said intersection in the opposite direction, turned left directly in front of Plaintiff, causing the vehicles to collide with one another. 6. The aforesaid collision was caused solely by the negligence of Defendant, as follows: a. Failing to yield the right-of-way to Plaintiff, b. Failing to stop for traffic having the right-of-way; C. Driving her vehicle directly into the path of Plaintiff's vehicle; d. Failing to keep her vehicle under proper control; Operating her vehicle without due regard for the rights, safety and position of the Plaintiff, 7 but not limited to, the following, some or all of which may be permanent: a. Fracture of the lateral malleolus of the right ankle; b. Fracture of the right patella; C. Soft tissue swelling at and around the fracture sites; d. Discoloration of the skin at or around the fracture sites; e. Pain, suffering and inconvenience; and f. Temporary immobility. f Failing to pay attention to Plaintiff's vehicle; and 9. Operating her vehicle in disregard for the rules of the road, the motor vehicle laws of Pennsylvania and the ordinances of Lower Allen Township. As a result of Defendant's negligence, Plaintiff suffered serious injuries, including 8. As a further result of Defendant's negligence, Plaintiff has been obliged to receive and undergo medical attention and care and has incurred expenses in an attempt to cure said injuries, and Plaintiff may be obliged to continue to expend such sums or incur such expenses for an indefinite period of time in the future. 9. As a further result of Defendant's negligence, Plaintiff has been prevented from pursuing her usual activities. 10. As a further result of Defendant's negligence, Plaintiff has suffered severe physical pain, mental anguish, humiliation and loss of enjoyment of life, and Plaintiff may continue to suffer same for an indefinite period of time in the future. WHEREFORE, Plaintiff demandsjudgment against Defendant in an amount in excess of the arbitration limits in Cumberland County. Dated: Ja,,'-- / Lv// CLECKNER AND FEAREN By Dennis J. Shatto, Esquire Attorneys for Plaintiff VERIFICATION I, MARY K. PRIMROSE, hereby verify and state that to the extent the foregoing Complaint contains facts supplied by me, they are true and correct to the best of my knowledge, information and belief, however, to the extent that the foregoing document and/or its language is that of counsel, I have relied upon counsel in making this verification. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: MARY P 61MROSE OWENS BARCAVAGE & MCINROY, LLC BY: Bart W. Holmes, Esquire PA ID No.: 85071 2595 Interstate Drive Harrisburg, PA 17110 717-909-2500 717-909-2504 (fax) ? 40 zEF;L?D COll3?T`r + " # SY LN! ail A MARY K. PRIMROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 10-959 MAUREEN M. MINDER, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED ANSWER WITH NEW MATTER AND NOW COMES, Maureen M. Minder, by and through her attorneys, OWENS BARCAVAGE & MCINROY, LLC, and Bart W. Holmes, Esquire, with the following Answer with New Matter. 1. After reasonable investigation answering defendant is without knowledge sufficient to form a belief as to the truth of the averments in this paragraph and therefore deny same. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part and denied in part. After reasonable investigation, answering Defendant is without information sufficient to form a belief as to the truth of whether Plaintiff entered the intersection intending to continue northbound on Wesley Drive. It is admitted that Defendant approached the same intersection in the opposite direction. It is admitted that Defendant turned left in front of Plaintiff. It is denied that Defendant's actions were the sole cause or factual cause of the collision. 6. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). a. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). b. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). c. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). d. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). e. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). f. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). g. The averments in this paragraph constitute conclusions of law to which no responsive pleading is required. In addition, same are denied under PA R.C.P. 1029(e). 7. This paragraph contains conclusions of law to which no responsive pleading is required. With respect to Plaintiff suffering injury or serious injuries, after reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore denies same. In addition, same are denied under PA R.C.P. 1029(e). a. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). b. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). c. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). d. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). e. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). f. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). 8. This paragraph contains conclusions of law to which no responsive pleading is required. Further, after reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). 9. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). 10. After reasonable investigation answering Defendant is without sufficient knowledge to form a belief as to the truth of this averment and therefore same are denied. In addition, same are denied under PA R.C.P. 1029(e). In addition, it is denied that Defendant's negligence was the sole cause of this accident. WHEREFORE, answering Defendant demands judgment against Plaintiff and in favor of Defendant NEW MATTER 11. Answering Defendant incorporates its responses to the foregoing paragraphs as if set forth at length herein. 12. Plaintiff's claims are barred by the Doctrine of Contributory Negligence. 13. Plaintiff's claims are barred by the Comparative Negligence Law. 14. Plaintiff's claims are barred by the Doctrine of Assumption of Risk. 15. Plaintiff's claims may be barred by a limited tort election under the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, answering Defendant demands judgment in its favor and against Plaintiff. O S BARCAVAGE & MCINROY, LLC Date: October 7, 2011 Bart W. Holmes, Esqui PA ID No.: 85071 2595 Interstate Drive Harrisburg, PA 17110 717-909-2500 717-909-2504 (fax) Attorney for Defendant (remainder of page intentionally left blank) VERIFICATION I, m U lA cet n M1ndcr (print name), certify under penalty of 18 Pa.C.S. § 4904, related to Unsworn Falsification to Authorities, that the averments of fact or things produced in the foregoing document are true and correct upon my personal knowledge, or information and belief. Date: 7+1111,2011 (signature) CERTIFICATE OF SERVICE I, Bart W. Holmes, Esquire, certify under penalty of unsworn falsification to governing authorities, that on this 7`" day of October 2011, I have served a true and correct copy of the foregoing, by United States Mail, pre-paid, as follows: Dennis J. Shatto, Esquire Cleckner and Fearen 119 Locust Street P.O. Box 11847 Harrisburg, PA 17108 BartW. Holmes, squi Attorney for Defednant CONNORS LAW,LLP ATTORNEYS FOR DEFENDANT By: Patricia Burns Horn, I.D. #66603 Maureen M. Minder Kevin L. Connors, I.D. #52819 140 S. Village Avenue, Suite 120 Exton, PA 19341 610.524.2100 MARY K. PRIMROSE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PAC . V. NO. 10-959 �m cn r rv , . MAUREEN M. MINDER, r-� �" �-+may Defendant CIVIL ACTION—LAW 4<° =�! =.b ' ENTRY OF APPEARANCE " y{ ' TO THE PROTHONOTARY: Kindly enter our appearances as counsel on behalf of Defendant, Maureen M. Minder, with regard to the above-captioned matter. Connors Law,LLP By: - l2 Patricia Burns Dorn, Esquire Kevin L. Connors, Esquire Attorneys for Defendant, Maureen M. Minder Date: OWENS, BARCAVAGE AND MCINROY, LLC BY: Stephen J. Bracavage Attorney I.D. No. 78867 2595 Interstate Drive, Suite 101 Harrisburg, PA 17110 (717) 909-2500 MARY K. PRIMROSE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 10-959 MAUREEN M. MINDER, : CIVIL ACTION—LAW Defendant : JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of the Defendant, Maureen M. Minder. OWENS BARCAVAGE AND MCINROY, LLC. DATE: BY: S en). B cavage, Esquire .D. o 67 2595 Interstate Drive Harrisburg, PA 17110 (717) 909-2500 CONNORs LAW,LLP ATTORNEYS FOR DEFENDANT By: Patricia Burns Horn, I.D. #66603 Maureen M. Minder Kevin L. Connors, I.D. #52819 140 S. Village Avenue, Suite 120 Exton, PA 19341 610.524.2100 MARY K. PRIMROSE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 10-959 MAUREEN M. MINDER, Defendant CIVIL ACTION—LAW CERTIFICATE OF SERVICE The undersigned counsel hereby certifies that on this day a true and correct copy of the Entry of Appearance Entry of Appearance and Withdraw of Appearance was served by first class mail,postage prepaid, addressed as follows: Dennis J. Shatto Cleckner and Fearen 119 Locust Street P.O. box 11847 Harrisburg, PA 17108 Stephen J. Barcavage, Esquire Owens Barcavage & McInroy, LLC 2595 Interstate Drive Suite 101 Harrisburg, PA 17110 CONNORs LAW,LLP By: Patricia Burns Horn, Esquire Attorney for Defendant, Maureen M. Minder Date: April 19, 2013 13-03491 AW/R CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 r mrn c -r n In the Matter of: Court of Common Pleas�— v o*•. MARY K. PRIMROSE Cumberland County tE " c MAUREEN M. MINDER No. 10-959 i ry As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of PATRICIA BURNS, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s)with a copy of the subpoena(s) attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s) which will be served is/are identical to the subpoena(s) which is/are attached to the notice of intent to serve the subpoena(s). /"f GCLLL _L,CG'O�'�5 DATE: 6/4/2013 PATRICIA BURNS, ESQUIRE Counsel for Defendant Center City Legal Reproductions, Inc. =CL 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ■ • • • (215)732-1177 fax (215)732-5637 Online Services www.ecirinc.com MARY K. PRIMROSE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. MAUREEN M. MINDER No. 10-959 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 Please take notice there has been a request by PATRICIA BURNS, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to MARY PRIMROSE. Enclosed is(are) a copy (copies)of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: June 4, 2013 Enclosures : Copy(copies)of Subpoena(s) Counsel Return Page Center City Legal Reproductions, Inc. C C LR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 • • • • (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com MARY K. PRIMROSE CCLR File NO. 13-03491AW/R VS. MAUREEN M. MINDER COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 6/4/2013 regarding records in the custody of(see attached subpoena(s)) and respond as follow: (1) COPIES yes I no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) 1 would like copies of X-Rays sent to me. yes/ no (3) OBJECTION In accordance to rules goveming civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions prior to 6/4/2013. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) 'would like to look at the records at a Center City location before yes I no deciding whether to order a copy. 2013 Copy FeeslPer Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61 &Above $.20 Date: Attorney for plaintiff(s)/defendant(s) DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K.PRIMROSE VS MAUREEN M. MINDER File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CO: FRANCIS X. PERNA, MD-MEDICAL RECORDS DEPT (Name of Person or Entit)) Within twenty(20)days after service of(his subpoena, you are ordered by the court to produce the following documents or things Any and all medical records, reports, office notes,progress reports,doctors notes,charts, summaries,test results, lab tests, evaluations,etc.,pertaining to Mary Primrose; DOB: 812/1963. "Certification Page Must Be Signed and Dated" AT CENTER CTTY LEGAL REPRODUCTIONS, INC (Address) You may deliverer mail legible copies of the documents or produce things requested by this subpoena, together with the certificate compliance, to (he party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the topics 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 is subpoena may Neck a court order compelling you to comply with it "f HIS SUBPOENA WAS ISSUED ATTHE REQUEST OF THE FOLLOWING PERSON: NAME: PAIRICIA BURNS, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET,SUITE 601 I'll I LADELPH IA, PA 19107 TELEPHONE: 215-732-1177 SUPREMECOUR] IDB kI"I'ORNfa FOR: DEFI!NDAN"1' f 6'i l l H[ ( OI k i ) IoCtuCuwl 1 thonotary CI G,,ID position Deputy Off T91) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K.PRIMROSE VS MAUREEN M. MINDER File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: JAMES F. RICH, MD -MEDICAL RECORDS DEPT (Name of P¢r.m.nr F.nm3) Within twenty(20)days after service of this subpoena, you are ordered by the court to produce the following documents or things Any and all medical records,reports,office notes,progress reports,doctors notes,charts,summaries,test results,lab tests, evaluations,etc., pertaining to Mary Primrose; DOB: 812/1967. "Certification Page Must Be Signed and Dated" (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. 'PHIS SUBPOENA WAS ISSUED ATTHF.REQUEST OF THE FOLLOWING PFRSON_ NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCE IONS, INC. 1315 WALNUT S'TREE'T,SUITE 60l PHILADELPILLA, PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT IDH ATTORNEY FOR: DEFENDANT 1)s,il 5 30�.� S" of the I Plothonol ('Icrk, C4Uispositmn _. . Deputy, (P7T7/97) 13-05537AW/R CERTIFICATE - PREREQUISITE TO SERVICE OF A SUBPOENA -nom rn r C= PURSUANT TO RULE 4009.22 ice , C) In the Matter of: Court of Common Pleas c i MARY K. PRIMROSE Cumberland County , w. i _VS MAUREEN M. MINDER No. 10-959 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of PATRICIA BURNS, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s)with a copy of the subpoena(s) attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s)which will be served is/are identical to the subpoena(s) which is/are attached to the notice of intent to serve the subpoena(s). DATE: 8/26/2013 PATRICIA BURNS, ESQUIRE Counsel for Defendant •■y'•' "` Center City .Legal Reproductions, Inc. CI T 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ■ ■ ■ ■ (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com MARY K. PRIMROSE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. MAUREEN M. MINDER No. 10-959 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 Please take notice there has been a request by PATRICIA BURNS, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to MARY PRIMROSE. Enclosed is(are) a copy (copies) of the subpoena(s)to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: August 26, 2013 Enclosures : Copy(copies)of Subpoena(s) Counsel Return Page Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 '— (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com MARY K. PRIMROSE CCLR File NO. 13-05537AW/R vs. MAUREEN M. MINDER COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 8/26/2013 regarding records in the custody of(see attached subpoena(s)) and respond as follow: (1) COPIES yes / no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) 1 would like copies of X-Rays sent to me. yes/ no (3) OBJECTION In accordance to rules governing civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions prior to 8/26/2013. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) 1 would like to look at the records at a Center City location before yes / no deciding whether to order a copy. 2013 Copy Fees/Per Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61 &Above $.20 Date: Attorney for plaintiff(s)/defendant(s) DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K.PRIMROSE VS MAUREEN M. MINDER File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR.OLUSOLA OSENDEKO—MEDICAL RECORDS DEPT (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: 13 Se of the Court Prothonotary/Clerk,,C-ivil Disposition Deputy (Eff.7/97) Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 --°=� (215)732-1177 fax (215)732-5637 CCLR File No. 13-05537AW/R ADDENDUM TO SUBPOENA To: DR. OLUSOLA OSENDEKO Re: MARY PRIMROSE ANY AND ALL MEDICAL RECORDS, BILLING RECORDS AND FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO MARY PRIMROSE; DOB: 08/02/1963. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** OF Tiv RoTF-FicE . O,�l'OTARY Dennis J. Shatto, Esquire / ,7 p Pa. Supreme Court ID #25675 1 N 1: 14 Cleckner and Fearen C UP1rERLANQ 119 Locust Street PE NNS YLVA ARTY P. 0. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 (Attorneys for Plaintiff) MARY K. PRIMROSE, - IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 10-959 • MAUREEN M. MINDER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED OBJECTIONS TO SUBPOENA PURSUANT TO RULE 4009. 21 Plaintiff, Mary K. Primrose, objects to the proposed subpoena that is attached to these objections for the following reasons: The records requested by this subpoena are not limited to conditions or treatment relevant to the right leg injuries sustained by Plaintiff in the automobile collection. Plaintiff has not made claim for loss of earnings or earning capacity. Respectfully sumbitted, CLECKNER AND FEAREN ,,IA1,0(d‘,- .m,Z , (i)-C2b-C44 NC1E)Cs Dated: October 4, 2013 By 0-c‘5\t `S . SI-‘ ,±tSj Dennis J. Shatto, Esquire Attorneys for Plaintiff g2=3 Center City Legal Reproductions, Inc. • CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 I 1 r • (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com MARY K. PRIMROSE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY • VS. • MAUREEN M. MINDER No. 10-959 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 Please take notice there has been a request by PATRICIA BURNS, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of(see enclosures). These records pertain to MARY PRIMROSE. - Enclosed is(are) a copy (copies) of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: September 17, 2013 Enclosures : Copy(copies)of Subpoena(s) Counsel Return Page • Center City Legal Reproductions, Inc. CLLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 1 1 1 6 1 1 1 1 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com - MARY K.PRIMROSE CCLR File NO. 13-06206AW/R vs. MAUREEN M. MINDER COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 9/17/2013 regarding records in the custody of(see attached subpoena(s)) and respond as follow: (1) COPIES yes / no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) I would like copies of X-Rays sent to me. yes / no (3) OBJECTION _ In accordance to rules governing civil procedure a copy of date/time stamped /ti tD filing needs to be sent to Center City Legal Reproductions prior to 10/8/2013. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) I would like to look at the records at a Center City location before yes / no deciding whether to order a copy. 2013 Copy Fees/Per Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61 &Above $.20 AO/' Date: dial/l3 Attorney for plaintiff(s)/defendant(s) DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG,,PA 11847 ' , • September 17, 2013 REQUEST DETAIL REPORT Page 1 REQUEST FOR FILE NUMBER: 13-06206AW/R Type: SUBPOENA-OTHER PA COUNTY Case#: 10-959 Date of Request: 9/10/2013 • MARY K. PRIMROSE Date Records Due: 10/23/2013 VS County/District: CUMBERLAND MAUREEN M. MINDER Pertains To: MARY PRIMROSE DOB: 08/02/1963 Address: 500 GENEVA DRIVE DOD/DOA: 02/21/2008 MECHANICSBURG,PA 17055 SSN: XXX-XX-4425 Claim#: 1556192258 B30 Requester:PATRICIA BURNS, ESQUIRE Phone: (610)524-2100 CONNORS LAW OFFICES, LLP Address: 140 S. VILLAGE AVENUE SUITE 120 Firm: EXTON, PA 19341 Additional Counsel on Request Attorney: DENNIS SHATTO, ESQUIRE Phone: (717)238-1731 Firm: - CLECKNER&FEAREN Fax: ( ) - Represents: PLAINTIFF September 17, 2013 REQUEST DETAIL REPORT Page 2 REQUEST FOR FILE NUMBER: 13-06206AW/R • Detail for ALL DEPONENTS on Request Deponent: HOLY SPIRIT HOSPITAL Phone: (717)763-2100 Department: MEDICAL RECORDS DEPT. Fax: ( ) - Address: 503 N. 21ST STREET Contact: CAMP HILL, PA 17011 Description Of Records:***SEE ATTACHED ADDENDUM *** Deponent: HOLY SPIRIT HOSPITAL Phone: (717)763-2100 Department: PATIENT BILLING DEPT Fax: ( ) -. Address: 503 N. 21ST STREET Contact: CAMP HILL, PA 17011 Description Of Records:***SEE ATTACHED ADDENDUM *** Deponent: HOLY SPIRIT HOSPITAL Phone: (717)763-2100 Department: RADIOLOGY FILE ROOM Fax: ( ) Address: 503 N.21ST STREET Contact: CAMP HILL, PA 17011 Description Of Records:*** SEE ATTACHED ADDENDUM *** COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K. PRIMROSE VS • MAUREEN M. MINDER File No. 10-959 . SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY - PURSUANT TO RULE 4009.22 • - TO: HOLY SPIRIT HOSPITAL—MEDICAL RECORDS DEPT (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is.subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107. TELEPHONE: 215-732-1177 - SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: . DATE: Seal of the Court Prothonotary/Clerk,Civil Disposition Deputy' • (Eff.7/97) Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R ************************** ADDENDUM TO SUBPOENA ************************** To: HOLY SPIRIT HOSPITAL - MEDICAL RECORDS DEPT. Re: • MARY PRIMROSE ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO MARY PRIMROSE.**CERTIFICATION PAGE MUST BE SIGNED AND DATED **(DOB: 08/02/1963) . ' COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND MARY K. PRIMROSE VS MAUREEN M. MINDER : • File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:HOLY SPIRIT HOSPITAL—PATIENT BILLING DEPT (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: CENTER CITY LEGAL REPRODUCTIONS,INC ' (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. • THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# V . ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: Seal of the Court 'Prothonotary/Clerk,Civil Disposition Deputy ' (Eff.7/97) , imorsomm Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 N I I I I E (215)732-1177 fax (215)732-5637 • • CCLR File No. 13-06206AW/R • ADDENDUM TO SUBPOENA To: HOLY SPIRIT HOSPITAL - PATIENT BILLING DEPT Re: MARY PRIMROSE ANY AND ALL BILLING RECORDS, INVOICES, PAYMENTS,RECEIPTS, PERTAINING TO MARY PRIMROSE. **CERTIFICATION PAGE MUST BE SIGNED AND DATED**(DOB:08/02/1963) • • COMMONWEALTH PENNSYLVANIA • COUNTY OF CUMBERLAND MARY K. PRIMROSE • VS • • MAUREEN M. MINDER " • • • File No. 10-959 • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 • TO: HOLY SPIRIT HOSPITAL—RADIOLOGY FILE ROOM (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) • You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE:215-732-1177 SUPREME COURT ID# • ATTORNEY FOR: DEFENDANT • BY THE COURT: • DATE: Seal of the Court Prothonotary/Clerk,Civil Disposition Deputy • • (Eff.7/97) • • • • • Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ° ° ° ° (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R *•************************* ADDENDUM TO SUBPOENA ************************** To: HOLY SPIRIT HOSPITAL- RADIOLOGY FILE ROOM Re: MARY PRIMROSE ANY AND ALL FILMS, MRI'S, CAT SCANS,X-RAYS, INCLUDING RADIOLOGY REPORTS, ETC., PERTAINING TO MARY PRIMROSE. **CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB:08/02/1963) 0 a o y , CERTIFICATE OF SERVICE I, JENNY A. TOBIAS, Secretary to Dennis J. Shatto, Esquire, hereby certify that on this day, I served a true and correct copy of the foregoing Objections to Subpoena Pursuant to Rule 4009 . 21 upon the person indicated below, by depositing same in the United States mail, first class postage prepaid, addressed as follows : Patricia Burns, Esquire Connors Law, LLP 140 S. Village Avenue, Suite 120 Exton, PA 19341 Va77/t/ 7311 Jenny A. Tobias Date: /0c/-43 13-06206AW/R CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 In the Matter of: Court of Common Pleas MARY K. PRIMROSE Cumberland County -VS MAUREEN M. MINDER No. 10-959 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of PATRICIA BURNS, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s)with a copy of the subpoena(s) attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. ' (4) The subpoena(s) which will be served is/are identical to the subpoena(s) which is re attached to the notice of intent to serve the subpoena(s). ngt- c-) o-rj -ter c P DATE: 10/8/2013 PA ' A BU' , ESQUIRE Counsel for Defendant Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ■ ■ ■ ■ (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com MARY K. PRIMROSE • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY • • VS. • MAUREEN M. MINDER No. 10-959 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 Please take notice there has been a request by PATRICIA BURNS, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to MARY PRIMROSE. Enclosed is(are) a copy (copies) of the subpoena(s)to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: September 17, 2013 Enclosures : Copy(copies)of Subpoena(s) Counsel Return Page Center City Legal Reproductions, Inc. C LR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com MARY K. PRIMROSE • CCLR File NO. 13-06206AW/R • • vs. • MAUREEN M. MINDER COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 9/17/2013 regarding records in the custody of(see attached subpoena(s)) and respond as follow: (1) COPIES yes/ no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) I would like copies of X-Rays sent to me. yes / no (3) OBJECTION In accordance to rules governing civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions prior to 10/8/2013. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) I would like to look at the records at a Center City location before yes / no deciding whether to order a copy. 2013 Copy Fees/Per Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61 &Above $.20 Date: Attorney for plaintiff(s)/defendant(s) DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K. PRIMROSE VS • • MAUREEN M. MINDER • File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL—MEDICAL RECORDS DEPT (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk,Civil Disposition Deputy (Eff.7/97) Center City Legal Reproductions, Inc. CLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 • • • • (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R ************************** ADDENDUM TO SUBPOENA ************************** To: HOLY SPIRIT HOSPITAL - MEDICAL RECORDS DEPT. Re: MARY PRIMROSE ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES,TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO MARY PRIMROSE. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED **(DOB: 08/02/1963) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K. PRIMROSE • VS • MAUREEN M. MINDER File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL—PATIENT BILLING DEPT (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk,Civil Disposition Deputy (Eff.7/97) Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 • • • • (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R ************************** ADDENDUM TO SUBPOENA ************************** To: HOLY SPIRIT HOSPITAL - PATIENT BILLING DEPT Re: MARY PRIMROSE ANY AND ALL BILLING RECORDS, INVOICES, PAYMENTS, RECEIPTS, PERTAINING TO MARY PRIMROSE. **CERTIFICATION PAGE MUST BE SIGNED AND DATED** (DOB: 08/02/1963) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K. PRIMROSE • VS • • MAUREEN M. MINDER • File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL—RADIOLOGY FILE ROOM (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS:CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: Seal of the Court Prothonotary(Clerk,Civil Disposition Deputy (Eff.7/97) Center City Legal Reproductions, Inc. CLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ' ' ' ' (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R ************************** ADDENDUM TO SUBPOENA ************************** To: HOLY SPIRIT HOSPITAL - RADIOLOGY FILE ROOM Re: MARY PRIMROSE ANY AND ALL FILMS, MRI'S, CAT SCANS, X-RAYS, INCLUDING RADIOLOGY REPORTS, ETC., PERTAINING TO MARY PRIMROSE. **CERTIFICATION PAGE MUST BE SIGNED AND DATED **(DOB: 08/02/1963) S 13-06206AW/R CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 In the Matter of: Court of Common Please r-t MARY K. PRIMROSE Cumberland County .�<.� ,D; _VS - C) MAUREEN M. MINDER No. 10-959 Zc+• �" r� As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of PATRICIA BURNS, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s)with a copy of the subpoena(s)attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s)which will be served is/are identical to the subpoena(s)which is/are attached to the notice of intent to serve the subpoena(s). DATE: 10/28/2013 A BURNS, QUIRE Counsel for Defendant Center City Legal Reproductions, Inc. C LR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 • (215)732-1177 fax (215)732-5637 Online Services www.ccIrinc,corn MARY K. PRIMROSE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. MAUREEN M. MINDER No.10-959 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 Please take notice there has been a request by PATRICIA BURNS, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of(see enclosures). These records pertain to MARY PRIMROSE. Enclosed is(are) a copy (copies) of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office, DATE: October 28, 2013 Enclosures Copy(copies)of Subpoena(s) Counsel Return Page Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ■__■, (215)732-1177 fax (215)732-5637 Online Services www.ceirinc.com MARY K. PRIMROSE CCLR File NO. 13-06206AW/R vs. MAUREEN M. MINDER . COUNSEL RETURN PAGE have received the Notice of Records Reproduction Request dated 10/28/2013 regarding records in the custody of(see attached subpoena(s)) and respond as follow: (1) COPIES yes / no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2), 1 would like copies of X-Rays sent to me. yes/ no (3) OBJECTION In accordance to rules governing civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions prior to 10/28/2013. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) 1 would like to look at the records at a Center City location before yes / no deciding whether to order a copy. 2013 Copy Fees/Per Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61 &Above $.20 Date: Attorney for plaintiff(s)/defendant(s) DENNIS SHATTO, ESQUIRE CLECKNER & FEAREN 119 LOCUST STREET HARRISBURG, PA 11847 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K.PRIMROSE VS MAUREEN M. MINDER File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL-MEDICAL RECORDS DEPT (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it, THIS SUBPOENA WAS ISSUED ATTHE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID9 ATTORNEY FOR: DEFENDANT BY THE COURT: DATE:'_ I Se of he Protho t /Clerk,Civil Disposition A911,-.e Deputy (Eff.7/97) Center City Legal Reproductions, Inc. LR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R ADDENDUM TO SUBPOENA To: HOLY SPIRIT HOSPITAL-MEDICAL RECORDS DEPT. Re: MARY PRIMROSE ANY AND'ALL MEDICAL RECORDS REGARDING TREATMENT FOR RIGHT AND LEFT LOWER EXTREMITY CONDITIONS OR OTHER CONDITIONS RELATED TO DIABETES, PERTAINING TO MARY PRIMROSE. CERTIFICATION PAGE MUST BE SIGNED AND DATED (DOB: 08/02/1963) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K.PRIMROSE VS MAUREEN M. MINDER File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL-PATIENT BILLING DEPT (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS:CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: .'2'j't_P_'tL Se of tAe* Court Prothonotary/Clerk,Civil Disposition Deput3(_ (Eff.7/97) Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ■!A! (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R ADDENDUM TO SUBPOENA To: HOLY SPIRIT HOSPITAL- PATIENT BILLING DEPT Re: MARY PRIMROSE ANY AND ALL BILLING RECORDS REGARDING TREATMENT FOR RIGHT AND LEFT LOWER EXTREMITY CONDITIONS OR OTHER CONDITIONS RELATED TO DIABETES, PERTAINING TO MARY PRIMROSE. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED**(DOB: 08/02/1963) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY K. PRIMROSE VS MAUREEN M. MINDER File No. 10-959 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL-RADIOLOGY FILE ROOM (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: CENTER CITY LEGAL REPRODUCTIONS,INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: PATRICIA BURNS,ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS,INC. 1315 WALNUT STREET,SUITE 601 PHILADELPHIA,PA 19107 TELEPHONE:215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: A Idz // ? -law Seal bf the C6111 PiothonotMarrk,Civil Disposition Civil le. Deputy'— (Eff.7/97) v Y Center City Legal Reproductions, Inc. CLLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 ■_! (215)732-1177 fax (215)732-5637 CCLR File No. 13-06206AW/R ADDENDUM TO SUBPOENA To: HOLY SPIRIT HOSPITAL- RADIOLOGY FILE ROOM Re: MARY PRIMROSE ANY AND ALL FILMS REGARDING TREATMENT FOR RIGHT AND LEFT LOWER EXTREMITY CONDITIONS OR OTHER CONDITIONS RELATED TO DIABETES, INCLUDING RADIOLOGY REPORTS, PERTAINING TO MARY PRIMROSE. *"CERTIFICATION PAGE MUST BE SIGNED AND DATED** (DOB: 08102/1963)