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Home My WebLink About10-3339.- jj ~:hr ` ~ ~ ILwri~ ', `', i'iL.l t,.. loco ~r~r i s ~~ ~~: ~ ~ W. Scott Henning, Esquire I.D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiffs Fax : (717) 233-3029 E-mail: Hennin HHRLaw.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2010 _333y ~iv~% Civil Action (XX) Law ( ) Equity JURY TRIAL DEMANDED KATHY J. SHATTO and WEST FAIRVIEW LEGION POST NO. 984 KENNETH W. SHATTO, her husband HOME ASSOCIATION a/k/a WEST FAIRVIEW 437 3'd St. AMERICAN LEGION POST NO. 984 Enola, PA 17025 611 3`d St. versus Enola, PA 17025 Plaintiff(s) & Defendant(s) & Address(es) Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwarded ()Attorn X)Sheriff W. Scott Henning Esauire Handler. Henning & Rosenberg LLP 1300 Linglestown Road 17171238-200017110 Sigp a ure ourt No. 298 ~~ ~ ~'~-~~ ~~ ~~~~~~ ~1~~ 10~i~1 Name/Address/Telephone No. of Attorney Date:_May 13. 2010 r~-r7 ya 33 .~ WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Prothon ary Date: Jt %~~/~ b Deputy ( )Check here if reverse is used for additional information PROTHON. - 55 WILLIAM J. FERREN & ASSOCIATES By: Patrick J. Moran, Esquire Attorney I.D. #61580 Ten Sentry Parkway, Suite 301 Blue Bell, PA 19422 2016 ??? )8 ? AA (215) 274-1701 (215) 274-1722 - Fax Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Kathy J. Shatto and No.: 2010-3339 Kenneth W. Shatto, her husband Civil Action - Law V. West Fairview Legion Post No. 984 Home Association a/k/a West Fairview American Legion Post No. 984 PRAECIPE TO FILE COMPLAINT To The Prothonotary: Please enter a Rule upon Plaintiffs, Kathy J. Shatto and Kenneth W. Shatto, to file a Complaint Against Defendant, West Fairview Legion Post No. 984 Home Association a/k/a West Fairview American Legion Post No. 984 within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. WILLIAM J. FERREN & ASSOCIATES By: Patrick J. M an, Esquire Attorney for Defendant RULE TO FILE COMPLAINT AND NOW, this I8"- day of , 2010, a Rule is hereby granted upon Plaintiff(s) to file a Complaint herein within twenty (20) days after service or suffer the entry of a Judgment of Non Pros. 1 OTH OTARY WILLIAM J. FERREN & ASSOCIATES By: Patrick J. Moran, Esquire Attorney I.D. #61580 Ten Sentry Parkway, Suite 301 Blue Bell, PA 19422 2A 10 ku& I? QAit Z; L? (215) 274-1701 (215) 274-1722 - Fax Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Kathy J. Shatto and No.: 2010-3339 Kenneth W. Shatto, her husband Civil Action - Law V. West Fairview Legion Post No. 984 Jury Trial Demanded Home Association a/k/a West Fairview American Legion Post No. 984 : ENTRY OF APPEARANCE AND DEMAND FOR JURY TRIAL TO THE PROTHONOTARY: Kindly enter my appearance as attorney for Defendant, West Fairview Legion Post No. 984 Home Association a/k/a West Fairview American Legion Post No. 984, in the above captioned matter. Defendant, West Fairview Legion Post No. 984 Home Association a/k/a West Fairview American Legion Post No. 984, by and through their undersigned counsel, hereby demand a trial by a jury of twelve. WILLIAM J. FERREN & ASSOCIATES By: Patrick J. Koran, Esquire Attorney for Defendant WILLIAM J. FERREN & ASSOCIATES I BLED-011-7rCE f Tk-!c c.. _ ,,,aiTw By: Patrick J. Moran, Esquire Attorney I.D. #61580 ,, 30 FM 3: Q 1 Ten Sentry Parkway, Suite 301 l ???" Blue Bell, PA 19422 (215) 274-1701 CUIvtt.n : ..?.1 i,JUNTY (215) 274-1722 - Fax Attorney for Defers aT n "LyM1A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Kathy J. Shatto and No.: 2010-3339 Kenneth W. Shatto, her husband Civil Action - Law V. West Fairview Legion Post No. 984 Home Association a/k/a West Fairview American Legion Post No. 984 CERTIFICATE OF SERVICE I, Patrick J. Moran, Esquire, hereby certify that I have served upon all persons listed below a true and correct copy of Rule to File Complaint in the above-captioned matter on August 25, 2010 by certified mail, return receipt requested #7099 3400 0011 8776 5362. W. Scott Henning, Esquire Handler, Henning & Rosenberg, L.L.P. 1300 Linglestown Road Harrisburg, PA 17110 WILLIAM J. FERREN & ASSOCIATES Patrick J. Moran, Esquire Attorney for Defendant r I w E ;U r?t 0 r! 0 TA R 201 1 V10 -8 10' 07 UMBERLAD COUNTY W. Scott Henning, Esquire I.D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax : (717) 233-3029 E-mail: Henning HHRLaw.com KATHY J. SHATTO and : IN THE COURT OF COMMON PLEAS KENNETH W. SHATTO, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. . NO: 2010-3339 Civil Term WEST FAIRVIEW AMERICAN LEGION : POST NO. 984 HOME ASSOCIATION a/k/a WEST FAIRVIEW AMERICAN LEGION POST NO. 984, Defendant CIVIL ACTION -LAW PLAINTIFFS' REPLY TO NEW MATTER AND NOW, comes the Plaintiffs, Kathy J. Shatto and Kenneth W. Shatto, by and through their attorney, HANDLER, HENNING & ROSENBERG, LLP, by W. Scott Henning, Esq., and responds to the Defendants' allegations of New Matter as follows: 26. Denied. The allegation set forth in paragraph 26 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiff, Kathy J. Shatto, denies that she was in any way contributorily or comparatively negligent with respect to the fall that she sustained, and hence, the Pennsylvania Comparative Negligence Act does not serve as a bar or reduction of Plaintiffs' claims for recovery, and proof to the contrary is demanded at the trial in this matter. 27. Denied. The allegation set forth in paragraph 27 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, it is denied that the Plaintiffs' claims for compensation for Plaintiff, Kathy J. Shatto's, injury are barred in whole or in part by the Doctrine of the Assumption of the Risk and/or Comparative Negligence, and proof to the contrary is demanded at the trial in this matter. By way of further answer, it is expressly denied that the Plaintiff assumed the risk of falling. By way of additional answer, the Plaintiffs assert that the Assumption of the Risk Doctrine would not be applicable to the subject cause of action. 28. Denied. The allegation set forth in paragraph 28 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, it is denied that the Plaintiffs' Complaint fails to state a cause of action upon which relief may be granted against the Defendant, and proof to the contrary is demanded at the trial in this matter. 29. Denied. It is denied that the Defendant was not negligent, careless or failed in its duties owed to the Plaintiff, Kathy J. Shatto, and proof to the contrary is demanded at the trial in this matter. 30. Denied. It is denied that the injuries and damages sustained by Plaintiff, Kathy J. Shatto, were caused by the acts or omissions of persons other than the Answering Defendant or caused by a person or entity over whom the Answering 2 Defendant had no control or right of control, and proof to the contrary is demanded at the trial in this matter. WHEREFORE, the Plaintiffs, Kathy J. Shatto and Kenneth W. Shatto, request the Honorable Court to enter judgment in their favor and against the Defendant, West Fairview Legion Post No. 984 Home Association a/k/a West Fairview American Legion Post No. 984, for the relief set forth in their Complaint. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP By: W" Scott Henniny kSupreme Court 1.11. # 1300 Linglestown Road Harrisburg, PA 17110 Henning(cD-hhrlaw.com (717) 238-2000 DATED: Attorney for Plaintiff 3 VERIFICATION PURSUANT TO PA R.C.P. NO. 1024 (c) W. SCOTT HENNING, ESQUIRE, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. Date: -5 7-,DC// W. SCOTT HENNING, ESQUIRE KATHY J. SHATTO and : IN THE COURT OF COMMON PLEAS KENNETH W. SHATTO, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO: 2010-3339 Civil Term WEST FAIRVIEW AMERICAN LEGION : POST NO. 984 HOME ASSOCIATION a/k/a WEST FAIRVIEW AMERICAN LEGION POST NO. 984, Defendant CIVIL ACTION -LAW 7 CERTIFICATE OF SERVICE On the--'?y of Fay, 2011, 1 hereby certify that a true and correct copy of Plaintiffs' Reply To New Matter was served upon the following by depositing in U.S. Mail; Patrick J Moran, Esq. William J. Ferren & Associates Ten Sentry Parkway, Suite 301 Blue Bell, PA 19422 HANDLER, HENNING & ROSENBERG, LLP Date: 7'Z2o i/ By: 11-6965R/G CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 In the Matter of: KATHY J. SHATTO _VS - WEST FAIRVIEW LEGION POST #984 rn Court of Common Pleas v, rr- i Cumberland County r - d te - n > M . - > C ) No. 2010-3339 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of PATRICK J. MORAN, 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: 10/11/2011 P AgK qM7RAN, ESQUIRE Counsel for Defendant 41116 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 KATHY J. SHATTO IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. WEST FAIRVIEW LEGION POST No. 2010-3339 #984 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS W. SCOTT HENNING, ESQUIRE HANDLER, HENNING & ROSENBERG 1300 LINGLESTOWN ROAD SUITE 2 HARRISBURG, PA 17110 Please take notice there has been a request by PATRICK J. MORAN, 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 KATHY J. BICKEY AKA SHATTO AKA COFFEY. 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 20, 2011 Enclosures : Copy (copies) of Subpoena(s) Counsel Return Page .i. Center City Legal Reproductions, Inc. CCLR 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 00 _ (215)732-1177 fax (215)732-5637 Online Services www.ccirinc.com KATHY J. SHATTO CCLR File NO. 11-6965R/G vs. WEST FAIRVIEW LEGION POST #984 COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 9/20/2011 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 10/11/2011. 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. 2011 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) W. SCOTT HENNING, ESQUIRE HANDLER, HENNING & ROSENBERG 1300 LINGLESTOWN ROAD SUITE 2 HARRISBURG, PA 17110 September 20, 2011 REQUEST DETAIL REPORT Page 1 REQUEST FOR FILE NUMBER: 11-6965R/G Type: SUBPOENA - OTHER PA COUNTY Case #: 2010-3339 Date of Request: 9/6/2011 KATHY J. SHATTO Date Records Due: 10/21/2011 VS County/District: CUMBERLAND WEST FAIRVIEW LEGION POST #984 Pertains To: KATHY J. BICKEY AKA SHATTO AKA DOB: 12/29/1957 COFFEY Address: 437 3RD STREET DOD/DOA: 6/1/2008 ENOLA, PA 17025 SSN: XXX-XX-5494 Claim #: A6C1255 Requester: PATRICK J. MORAN, ESQUIRE Phone: (215)274-1700 WILLIAM J. FERREN & ASSOCIATES Address: 10 SENTRY PARKWAY SUITE 301 Firm: BLUEBELL, PA 19422 Additional Counsel on Request Attorney: W. SCOTT HENNING, ESQUIRE Phone: (717)238-2000 Firm: HANDLER, HENNING & ROSENBERG Fax: (717)233-3029 Represents: PLAINTIFF September 20, 2011 REQUEST DETAIL REPORT Page 2 REQUEST FOR FILE NUMBER: 11-6965R/G Detail for ALL DEPONENTS on Request Deponent: EAST PENNSBORO AMBULANCE SERVICE Phone: Department: RECORDS DEPT Fax: Address: 750 SOUTH HUMER STREET Contact: ENOLA, PA 17025-2622 Description Of Records: ANY AND ALL RECORDS, REPORTS, DOCUMENTS, ANY WRITTEN INFORMATION PERTAINING TO KATHY J. BICKEY AKA SHATTO AKA COFFEY; ADDRESS AT TIME OF THE ACCIDENT: 28 BUTTONWOOD LANE, CARLISLE, PA 17015. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** Deponent: GRANDVIEW SURGERY CENTER Phone: ( ) - Department: MEDICAL RECORDS DEPT Fax: ( ) - Address: 179 LANCASTER BOULEVARD Contact: MECHANICSBURG, PA 17055-3580 Description Of Records: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KATHY J. RICKEY AKA SHATTO AKA COFFEY. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** Deponent: HOLY SPIRIT HOSPITAL Phone: (717)763-2100 Department: MEDICAL RECORDS DEPT. Fax: ( ) - Address: 503 N. 21 ST STREET Contact: CAMP HILL, PA 17011 Description Of Records: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KATHY J. BICKEY AKA SHATTO AKA COFFEY. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** Deponent: HOLY SPIRIT HOSPITAL Department: RADIOLOGY FILE ROOM Address: 503 N. 21 ST STREET CAMP HILL, PA 17011 Phone: (717)763-2100 Fax: ( ) - Contact: Description Of Records: ANY AND ALL RADIOLOGY REPORTS PERTAINING TO KATHY J. RICKEY AKA SHATTO AKA COFFEY. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** . September 20, 2011 REQUEST DETAIL REPORT Page 3 Deponent: ROBERT MATSKO, SR., DO Phone: ( ) - Department: BROAD STREET FAMILY HEALTH CENTER Fax: ( ) - Address: 211 BROAD STREET Contact: MARYSVILLE, PA 17053-1302 Description Of Records: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KATHY J. BICKEY AKA SHATTO AKA COFFEY. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** Deponent: STEVEN M. DELUCA, D.O. Phone: Department: ORTHOPEDIC INSTITUTE OF PA Fax: ( ) - Address: 3399 EAST TRINDLE ROAD Contact: CAMP HILL, PA 17011 Description Of Records: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KATHY J. BICKEY AKA SHATTO AKA COFFEY. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** Deponent: TRISTAN ASSOICATES Phone: ( ) - Department: MEDICAL RECORDS DEPT Fax: ( ) - Address: WEST SHORE OFFICE Contact: 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 Description Of Records: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KATHY J. BICKEY AKA SHATTO AKA COFFEY. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** Deponent: WEISS PHYSICAL THERAPY ASSOCIATES PC Phone: ( ) - Department: MEDICAL RECORDS DEPT Fax: ( ) - Address: 1700 BENT CREEK BOULEVARD Contact: SUITE 120 MECHANICSBURG, PA 17050-1870 Description Of Records: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KATHY J. BICKEY AKA SHATTO AKA COFFEY. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** COMMONWEALTH OF PENNSYLVANIA COtTNTY OF CUMBERLAND KATHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: EAST PENNSBORO AMBULANCE SERVICE - 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 Any and all records, reports, documents, any written information pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY; Address at time of the accident: 28 Buttonwood Lane, Carlisle, PA 17015. 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: PATRICK J. MORAN, 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 DATE: "l { S I I. Sea. of the Coto t BY THE COURT: r Prothonotary /Clerk, Civil Disposition Dep (Eff.7/97) CO'.NLMOINTWEALTH 0- F PENNSYLVANIA COUNTY OF C1JMBEPLAN D KATHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2:! TO: GRANDVIEW SURGERY CENTER - MEDICAL RECORDS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the count to produce the following documents or things Any and all medical records, reports, office notes, progress reports, doctors notes, chairts, summarises, test results, lab tests, evaluations, etc., pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY. AT: CENTER CITY LEGAL REPRODUCTIONS, INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this s abpoeni?, 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 PER30114: NAME: PATRICK J. MORAN, 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: Ct I S I I ? 1 -.??z -, Seal o the Court rothonotary /C1erkC'ivil Disposition Deputy (Eff.7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLANI) KATHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 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 Any and all radiology reports pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY. 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: PATRICK J. MORAN, 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: S "'N eal of the Court Prothonotary /C ,jerk, Civil Disposition Deputy (Eff.7/97) COMMONWEALTH OF PENNSYLVANIA, COUNTY OF CUMBERLAND KATHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 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 Any and all medical records, reports, office notes, progress reports, doctors notes, charts, summaries, test results, lab tests, evaluations, etc., pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY. 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: PATRICK J. MORAN, 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 DATE: qhshl A al o the Court BY THE COURT: :hOAAe'eL? .-Ljj- , A Prothonotary/Clprk, Civil Disposition Deputy (Eff.7/97) COMMONWEALTH OF .PE N1.NSYLVA1VIA. COUNTY OF CUMBERLAND KATHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ROBERT MATSKO, SR., DO - BROAD STREET FAMILY HEALTH 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 Any and all medical records, reports, office notes, progress reports, doctors notes, charts, summaries, test results, lab tests, evaluations, etc., pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY. 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: PATRICK J. MORAN, 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 C11/sh/ DATE: 9&1 o the Court (Eff.7/97) BY THE COURT: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KATHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: STEVEN M. DELUCA, D.O. - ORTHOPEDIC INSTITUTE OF PA (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 Any and all medical records, reports, office notes, progress reports, doctors notes, charts, summaries, test results, lab tests, evaluations, etc., pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY. 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: PATRICK J. MORAN, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET, SUITE 601 PHILADELPHIA, PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ED# ATTORNEY FOR: DEFENDANT BY THE COURT: DATE: S al othe Court thonotary /Clerk, Civil Dispose ion Deputy (Eff.7/97) COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND MTHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: TRISTAN ASSOICATES - 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 Any and all medical records, reports, office notes, progress reports, doctors notes, charts, summaries, test results, lab tests, evaluations, etc., pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY. 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: PATRICK J. MORAN, 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: 911, S GI of a .ourt Prothonotary / ler Civil Disposition Deputy (Ef1:7/97) COMMONWEALTH OF PEYNSYLVANTA C O'[1raY OF C UMBERLAND KATHY J. SHATTO VS WEST FAIRVIEW LEGION POST #984 File No. 2010-3339 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WEISS PHYSICAL THERAPY ASSOCIATES PC - 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 Any and all medical records, reports, office notes, progress reports, doctors notes, charts, summaries, test results, lab tests, evaluations, etc., pertaining to KATHY J. BICKEY AKA SHATTO AKA COFFEY.- 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: PATRICK J. MORAN, 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: r DATE: qjl,5k " I.S Seal of the Court ProthonotaD /Cl Cavil Disposition Deputy (Eff.7/97) B°"fl' Pro*honotary +/�./�*°`�� [�/�e��/u��oy�oh7r� �u '� `_/ ~-'-o`-~Q Solicitor /0-3339 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTiCE OF iNTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH QYTHE COURT, DAVID D. BUELL