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Home My WebLink About01-1008DIANE M. LIBERATORE, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN p. BLESSING, v. Plaintiff [ CIVIL ACTION _ LAW NO. C'I- /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 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 NOT HAVE LAWYER OR CA'~ .... YOUR LAWYER AT O~c~ - _ SET FORTH Br~r,-, ........ ~'~ul AFFORD ONE. G _~ ..... IF YOU DU out WHE YOU T.E OFFICE ~'~- -~uAL HELP. Cumber/and County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 204788. l \RAS~vl LB JOHN p. BLESSING, 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DIANE M. LiBERATORE, Defendant CIVIL ACTION _ LAW NO. JURY TRIAL DEMANDED NOTICIA Le hah demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnu/entes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apar/encia escfita o en persona o pot abogado Y archivar en la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y pot cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE SI ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE P ~^~ .... L' NO TIENE EN PERSONA O LLAME POR TELEPFONO A LA OFICINA CUYA DIRECCION SE A,~r~ ~L ~ERVICIO, VAYA ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 204788.1 \RAS\MLB JOHN p. BLESSING, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA Plaintiff V. DIANE M. LIBERATORE, Defendant CIVIL ACTION _ LAW NO. JURY TR/AL DEMANDED COMPLAINT I. Plaintiff John p. Blessing is an adult individuals, and citizens of the Commonwealth of Pennsylvania, who reside at 1925 Columbia Avenue, Pennsylvania. Camp Hill, Ctunberland County, 2. Defendant Diane M. Liberatore is an adult individual and citizen of the Commonwealth of Pennsylvania, who resides at 2161 (A) Market Street, Camp Hill, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about May 6, 1999, at approximately 2:00 p.m., on State Street in Lemoyne, Cumberland County, Pennsylvania. C°r°lla'4. At that time and place, Plaintiff John p. Blessing was operating a 1995 Toyota 5. At that time and place, Defendant Diane M. Liberatore was operating a vehicle and was traveling directly behind Pla/ntiffJohn p. Blessing's veh/cle. 6. At that time and place, PlahatiffJohn p. Blessing's vehicle was at a complete stop at a traffic light on State Slreet, Lemoyne, Cumberland County, Pennsylvania. 7. At that time and place, Defendant Diane M. Liberatore operated her vehicle at a high rate of speed, without paying attention to traffic, and suddenly and without warning, violently slammed into the rear of Plaintiff John p. Blessing's vehicle. 8. At that time and place, a violent collision occurred between the front portion of Defendant Liberatore's vehicle and the rear portion °fPlaintiffBlessing,s vehicle. 9. The foregoing accident and ail of the injuries and damages set forth hereinafter sustained by Plaintiff John p. Blessing are the direct and proximate result of the negligent, careless, wanton, and reckless manner in which Defendant Diane M. Liberatore operated her vehicle as follows: (a) failure to have her vehicle under such control as to be able to stop within the assured clear distance ahead; (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) failure to travel at a safe speed; (d) failure to apply her brakes in sufficient time to avoid striking the rear of the Blessing vehicle; (e) failure to take reasonable evasive action to avoid the accident; (f) failure to drive her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; (g) failure to keep proper and adequate control over her vehicle; (h) failure to stop for a traffic signal; and 2257881\RAS\LAM 2 (i) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with care/ess disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. As a result of the aforementioned accident, Plaintiff John p. Blessing sustained painful and severe injuries which include, but are not limited to, cervical and thoracic strain, left hand numbness, aggravation ora previous low back injury and headaches. 11. By reason of the aforesaid injuries sustained by Plaintiff John p. Blessing, he was forced to incur liability for medical treatment, medications, hospitalizations, and similar m~scellaneous expenses m an effort to restore himself to health, and claim is made therefor. 12. Because of the nature of his injuries, Plaintiff John p. Blessing has been advised and, therefore, avers that he may be forced to incur similar expenses in the future, and claim is made therefor. 13. As a result of the aforementioned injuries, Plaintiff John p. Blessing has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out his daily activities, loss of life's ,~J .... w~a~ures ana enjoyment, and claim is made therefor. 14. As a result of the aforementioned collision and resulting injuries, Plaintiff John p. Blessing has sustained loss of opportunity and a permanent diminution of his earning power and capacity, and claim is made therefor. 15. As a result of the aforesaid injtwies, Plaintiff John p. Blessing has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 225788 1 ~S\LAM 16. Plaintiff John p. Blessing continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries may be of a permanent nature, causing residual problems for the rema/nder of his lifetime, and claim is made therefor. WHEREFORE, Pla/ntiff John p. Blessing demands judgment against Defendant Diane M. Liberatore in an amount in excess of Twenty-Five Thousand Dollars ($25,000.00), exclusive of interest and costs and in excess ofanyjurisdictiona/amount requiring compulsory arbitration. Date: February 19, 2001 R, P.C. 4503 North Front Street Harr/sburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 2257881~S\LAM VERIFICATION I, John p. Blessing., Plaintiff, have read the foregoing PLAINTIFF,S COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my know/edge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. Dated: '/'~//o / ~ 225935. I\RAS\MLB SHERIFF'S CASE NO: 2001-01008 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BLESSING JOHN P VS LIBER3kTORE DIANE M SHAWN HARRISON RETURN - REGULAR Cumberland County,Pennsylvania, says, the within COMPLAINT LIBERATORE DIANE M , Sheriff or Deputy Sheriff of who being duly sworn according to & NOTICE was served upon the law, DEFENDANT at 0009:59 HOURS, at 2161 (A) MARKET ST CAMP HILL, PA 17011 DIANE LIBERATORE on the 23rd day of February , 2001 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.30 Affidavit .00 Surcharge 10.00 .00 37.30 Sworn and Subscribed to before me this ~ ~ day of A.D. //P~ot honot ary So Answers: R. Thomas Kline 02/26/2001 ANGINO & ROVNER Jefferson J. Shipman, Esquire I.D. #51785 GOLDBERG, KATZb~tEN & SHIPPU~N, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 284-4161 Counsel for Defendant JOHN P. BLESSING, Plaintiff DIANE M. vs. LIBERATORE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERL~LND COUNTY, PENNSYLV~LNIA : CIVIL ACTON - LAW : : NO. 01-1008 Civil Term : JURY TRIAL DEM3~NDED TO THE PROTHONOTAi%Y: PLEASE enter the PRAECIPE appearance of the undersigned on behalf of the Defendant in the above-captioned matter. DATE: 3/9/0i ' 60048.1 GOLDBERG, KATZM3LN & SHIPM3~N, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on ~rch 9. 2001: copy Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff 60048. 1 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant Jefferson J. Shipman, Esquire I.D. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendant JOHN P. BLESSING, : IN THE COURT OF COMMON PLEAS OF DIANE M. Plaintiff VS. LIBERATORE, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTON - LAW : : NO. 01-1008 Civil Term : JURY TRIAL DEMANDED TO: Plaintiff and his Attorney, Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 YOU ARE HEREBY notified to plead to the within New Matter of Defendant, Diane M. Liberatore, within twenty (20) days of service hereof. DATE: 60076.1 GOLDBERG, KATZMAN & SHIPMAN, P.C. ~ff~rson O. Shipman, Esquire 3/20 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant Jefferson J. Shipman, Esquire I.D. #51785 GOLDBERG, ~ATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendant JOHN P. BLESSING, : IN THE COURT OF CON~MON PLEAS OF Plaintiff : CUMBERL~tND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTON - LAW : DIANE M. LIBEP~ATORE, : NO. 01-1008 Civil Term Defendant : JURY TRIAL DEMANDED ANSWER AND NEW MATTER AND NOW, comes the Defendant, Diane M. Liberatore, through her counsel, Goldberg, Katzman & Shipman, P.C., the following ~nswer and New Matter: 2. 3. approximately 2:00 P.M. Admitted. Admitted. Admitted that the accident occurred on May By way of further response, by and and files 6, 1999 at it is believed that Cumberland County, Pennsylvania. 4. Corolla. response are denied. the accident occurred on Hummel Avenue in Lemoyne, Admitted that the Plaintiff was operating a 1995 Toyota Any remaining averments of paragraph 4 requiring a 5. Admitted that the Defendant Liberatore was operating a vehicle behind the Plaintiff. Any remaining averments of paragraph 5 requiring a response are denied. 6. Denied. After reasonable investigation the Defendant Liberatore is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph No. 7 and the same are, therefore, denied. 7. Denied. The averments contained in Paragraph 7 are conclusions of law to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 8. Denied. The averments contained in Paragraph 8 are conclusions of law to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 9. Denied. The averments contained in Paragraph 9, subparagraphs a. through i., are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. By way of further response it is specifically denied that the answering Defendant was negligent, careless, wanton and reckless in any manner with respect to Plaintiff's alleged caused of action. a. It is specifically denied that the Defendant failed to have her vehicle under such control so as to be able to stop within the assured clear distance ahead; b. It is specifically denied that the Defendant failed to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; c. failed d It is specifically denied that the Defendant to travel at a safe speed; failed to apply her brakes in sufficient time striking the rear of the Blessing vehicle; e. It is specifically denied that the Defendant failed to take reasonable evasive action to avoid the accident; f. It is specifically denied that the Defendant failed to drive her vehicle with due regard for the highway and traffic which were existing and of which she was or should have been aware; g. It is specifically denied that the Defendant failed to keep proper and adequate control over her vehicle; h. It is specifically denied that the Defendant failed to stop for a traffic signal; and It is specifically denied that the Defendant to avoid i. It is specifically denied that the Defendant drove her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard for the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. Denied. After reasonable investigation the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 10 relating to Plaintiff's alleged injuries and the same are therefore denied and strict proof demanded at the time of trial. 11. Denied. After reasonable investigation the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 11 relating to Plaintiff's alleged medical treatment. The averments are therefore specifically denied and strict proof demanded at the time of trial. 12. Denied. After reasonable investigation the answering Defendant is without sufficient knowledge or information to form a belief as to the truth ,of the averments contained in Paragraph 12 relating to Plaintiff's alleged expenses. The averments are therefore specifically denied and strict proof demanded at the time of trial. 13. Denied. After reasonable investigation the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 13 relating to Plaintiff's alleged injuries and the same are therefore denied and strict proof demanded at the time of trial. 14. Denied. After reasonable investigation the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 14 and the same are therefore denied and strict proof demanded at the time of trial. 15. Denied. After reasonable investigation answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 15 relating to Plaintiff's alleged great humiliation and embarrassment and the same are therefore denied and strict proof demanded at the time of trial. 16. Denied. After reasonable investigation answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 16 relating to Plaintiff's alleged injuries and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant, Diane M. Liberatore, respectfully requests that judgment be entered and that Plaintiff, s Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and reply the Defendant, Diane M. Liberatore, interposes the following New Matters: 17. That this action is subject to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. §1701, et ~eq. 18. That Plaintiff's claims may be "Limited Tort" Option, pursuant to 75 Pa. 19. That if it should be found that negligence on the part of the Defendant, which negligence is expressly denied, any such negligence was not a proximate cause of any damages to the Plaintiff. 20. That if the Plaintiff suffered any injuries or damages, as alleged in his Complaint, those injuries and damages were caused in whole or in part by the negligence of Plaintiff, and recovery in this action is barred or diminished in accordance with the Pennsylvania Comparative Negligence Act, 42 Pa. C.S.A. §7102, et .seq. limited or barred by the C.S.A. §1705, e_~t sec. there was any 21. That the Plaintiff's cause of action may be barred by the applicable Statute of Limitations. 22. That the Plaintiff's accident and any injuries sustained may have been caused in whole or in part by the negligence of third persons or entities not presently involved in this action. 23. That the Plaintiff assumed the risk of injuries allegedly sustained by him by reason of his own negligence carelessness. and WHEREFORE, the Defendant, Diane M. Liberatore, respectfully requests that judgment be entered in her favor and that Plaintiff's Complaint be dismissed with prejudice. Respectfully submitted, GOLDBERG, KATZNLAN & SHIPNL~N, P.C. 60075.1 ~fferson J. Shipman, Esquire F20 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant VERIFICATION I, Diane M. Liberatore, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 60081.1 CERTIFICATE OF SERVICE I hereby certify that I served a copy of document upon the person(s) of the same Harrisburg, the foregoing indicated below by depositing a copy in the United States mail, postage prepaid, at Pennsylvania, on March 14, 2001: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff 60049.1 GOLDBERG, KATZMAN & SHIPMAN, P.C. Jefferson J. Shipman, Esquire Attorney I.D. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN P. BLESSING, Plaintiff DIANE M. LIBERATORE, Defendant CIVIL ACTION - LAW NO. 01-1008 Civil Term JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER AND NOW comes the Plaintiff, by and through his attorneys, Angino & Rovner, P.C., and hereby enter the following Reply to the New Matter of Defendant as follows: 17. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, all of Plaintiffs injuries and damages are recoverable in the instant action. The Pennsylvania Motor Vehicle Financial Responsibility Law in no way limits the damages Plaintiff may recover herein. 18. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, the Plaintiff selected the full tort option on his policy and is, therefore, entitled to maintain an action for non-economic losses. Further, Plaintiff did suffer a serious injury. Plaintiffs Declaration Page is attached hereto as Exhibit A. 19. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the avem~ent may be deemed factual, it is hereby specifically denied. By way of amplification, Defendant's negligence was in fact the proximate cause of the damages sustained by Plaintiff. Further, all of Plaintiff's injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 20. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff was not negligent in any way. Therefore, the Pennsylvania Comparative Negligence Act does not apply to the instant action. Further, all of Plaintiffs injuries and damages are recoverable in the instant action and are in no way reduced. 21. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiffs Complaint was filed well within the applicable statute of limitations. 22. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Defendant's averment lacks the specificity required by the Pennsylvania Rules of Civil Procedure. Purther, all of Plaintiffs injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 228546. I\RAS~VlLB 23. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff did not assume the risk of his/her injuries. Further, as previously stated herein, Plaintiff was not negligent or careless. All of Plaintiffs injuries and damages are recoverable in the instant action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to dismiss Defendant's Answer and New Matter and enter judgment in his favor against the Defendant. ANGINO & ROVNER, P.C. J I.D. No. 47281 (/ 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff Date: March 30, 2001 228546. I\RAS\MLB . . ... ............iii,,-..,o ,. N T VERIFICATION I, John P. Blessing., Plalmiff, have read the foregoing PLAINTIFF'S REPLY TO NEW MATTER and do hereby swear or affirm that the facts set forth in the foregoing are tree and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. Dated: ~p. Ble/Os~ing~ ' ~ 225935. I\RAS\MLB CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a tree and correct copy of PLAINTIFF'S on the following via postage prepaid, first class United States mail, requested addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman 320 Market Street P.O. Box 1268 Han'isburg, PA 17108-1268 Mailc3; L. l~r'ym-~sse~ ' Date: March 30, 2001 228546 1 ~ASLMLB CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN p. BLESSING -rS- DIANE M. LIBERATOKE COURT OF COMMON PLEAs TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of __JEFFERSON j. SHIPMAN, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was ~ailed 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE:__08/14/200] Attorney for DEFEND-~T~-~ DEll-272559 65950_L01 COI~IlVlOSIIgI~ALTH OF PENNSYLVANIA COUSITy OF CIJI~BERLAND IN THE MATTER OF: JOHN p. BLESSING -VS- DIANE M. LIBERATORE COURT OF COMMON PLEAS TERM, CASE NO: 01-1008 [ Note: see enclosed list of locations ] TO: RIC~ARDA. SADLOCK, MCS on behalf of~F~SON j. SNIPHAI~, ESqUIR~ intends to serve a identical to the one that is attached to this notice Yo ' subpoena - u nave t~enty (20) days fr~ the date listed belo~ in~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t~nty day notice period is vaived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same toM CS or by contacting our local M~S office. DATE: 07/24/2001 CC: JEFFERsoN J. SHIPNAN, ESQUIRE - 22740-1068 MCS on behalf of JEFFgRSON j. SHII94A~, ESqWIRE Attorney for DE~NDANT Any questions regarding this matter, contact T~ HCS GROUP INC. 1601 MA~? STreET f800 PNIL/~ELPHIA, PA 19103 (215) 246-0900 DE02-159763 65950--C01 LOCA_~TION LIST <<~._~< LOCATION NAME PAGE: REHAB OPTIONS COMITY OSTEOPATHIC HOSP. COI~4UNITY OSTEOPATHIC HOSP. PINNACLE HEALTH HOSPITALS PINNACLE HEALTH HOSPITALS STEELTON P~ILy M~DICINE ASSO~ ARLINGTON ORTHOPEDIC PENNSYLVANIA N~UKO ASSOC. HCCUEN & ASSOCIATEs, PT DE02-159763 65950--C01 - COMMONWEALTH OF PENNSYI. VANi~ COUNTY OF CUMBERL.&ND JOHN P. BLESSING : VS : DIANE M. LIBERATORE : FHe No. _ 01-1008 CIVIL SUBPOENA TO PRODUCE DOCUMr,~-N-rs OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009 ~.Z2 TO: CUSTODIAN OF REOCRDS FOR: REHAB. OPTIONS " ' '"" ' ' ' ' ' = ' ' Ithe route to produce the following dOCUments or things: SEE ATTACHE~ at __ C GROUP INC. 1601 MA~E~ Yo~_ma.~ de,.er or ma~l legible copic~ of the documents or tOduce t ' . cern:]cate ~ compliance, to the parry ma.kin t ' P hirt~ re~I~e~ted bv t ad~ amce, the .'~-a$onable cost -.' --- ° · g his. request, at the addre~ t;.*~., ~_ . hie subpoena, to~ether with ,.- ~..epamng the cop~es or producino .*- .... --~,,~ a~ove. You have the right t,~ ..... l£ you fa/I to .:Voduce the documents ot things required by this subpoena, w~"~in tWenty. (20) c~avs after its sen'ice, the parry serving this ~ubpoena may s~k a court order compelling'you to comply with F_ ' . THIS SUBPOENA WAS ISSUED AT T'HE REQU~.S'r OF ~ FOLLOWING PERSON: NAME: __ JEFFF, R~ON j. SHTPM~N, ESQ. ADDRF.~S: 320 MARKET ST., PO BX 1268 -- -- HARRISBURG~ PA 17108 TEL~PHON-'. 215-246-0900 SUPREME COURT ID #: __ -- ATTOR.N~. ~OR~ DEFENDANT Seal of the Com't COURm ........ (Eff. 7/9~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: REHAB OPTIONS 2645 N. THIRD STREET ATE 460 HARRISBURG, PA 17110 RE: 65950 JOHN p. BLESSING ANY AND ALL MEDICAL RECORDS, CORRESPONDENCE, REPORTS, DIAGNOSTIC TESTS INCLUDING PHYSICAL THERAPy REPORTS & X-RAY REPORTS Subject: JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security ~.- 199-54-7963 Date of Birth: 04-22-1962 SU10-318970 65950--L01 PPA'I~q~-ISI~ ?0 SEII¥ICE OF A SI~POEI~ PI~sIIAI~ ?0 RIFLE 4009.22 IN THE MATTER OF: JOHN p. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO[g{ON PLEAs TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON j. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE:~08/14/200~ MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272560 65950--L02 ¢ O~{~iO ~r~q~%I~ T H OF PENN S l~_~V~%/~iA COIII~Ty OF CLSVlBERL~%/~D IN THE MATTER OF: JOHN p. BLESSING D~EM. -VS- LIBERAToRE COURT OF C0~0N PLEAS TERM, CASE NO: 01-1008 -,--~,o ~u~ DISCOVERy~ AND [ Note: see enclosed list of locations ] TO: HICHARD A. SADLOCK, ESOUI~e MCS on behalf of 3E~e.~ON'~ -~ identical to the one tha;"i;'a~c~ed'_ES.~.UI..RE /ntonds to serve a sub e days fr~ the date 14 ....... .eu =o ~nls notice. You have ~w~., · -o~eu an objection to the subr.~ena I~ .'~= .~ recore and serve upon the waited or if no objection t, made, ~en ~._._..r~_e ~wenty day notice period is ~:,_e.s._o_f.a~.y reproduced records may be O~ie;;lP-~-~ may be served. C~aplet, --. "k~_.acneo counsel card and return/n, s--- -~ .~_c your expense by completino rv~ oz~lce. ~ --~ uo ~S or by contact/nE our loc~l DATE= 0712412001 CC: J~"~ff, SON J. SHIPM&N, ESQUIRE- 22740-1068 ~CS on behalf of _JEFFERSON j. SHIPMAN, Attorney for D~DANT any questions re~ardinE this matter, contact THE HCS GROUP INC. 1601 H~I~T f800 PHXLADgLPHXA, PA 19103 (215) 246-0900 DE02-159763 65950--C01 ~CO~DS R~qUESl'ED oT~n X-RAY' X-~y O~y ~I~ ~CO~S DK02-159763 65950--C01 . COMM~O~...b~_ ALTH OFPENN?SYi. VANL JOHN p. BLESSING VS DIANE M. LIBERATORE F~Ie No. __01-1008 CIVIL SUBPOENA TO PRODUCE DOCUM~-FS OR THINGS FOR DISCOVERY PURSUA_NT TO RULE 4009Z22 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL things: . :'-~l oays a~ter service of ti'~is subpoena, you ate Ordered by the court to produce the following dOCuments or YO~ ~rnay dei/~.er or mail le~b · copies of the dOCuments or produce tl'~i cerrmca,e o.' compliance, to ,he parry making this reques, at ,he ,d~sTm.~:~Sc~teed. bv ,h~, subpoena. 'oge, her with the advance, the .~Uonable cost of prepatin~ the copies or producing the th. in~s sought. ~ou have the right to seek, in I£you fall to .:'roduce the dOCuments or things required by this subpoena, w'itb~i:l rwen~ (20) days a,ftet its sera. ice. the patty serving t;~s subpoena may seek a court order COmpelling you to comply with iL . THIS SL'SPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:: NAME: _ .TEVFRR~ON .!. SW'I'PMRN. ESO. ADDRF. SS: 320 btARKET ST., PO BX 1268 -- d~LaZRISBURG, PA 17108 TELEPIqoN~ ~.j. 5_246_0~00 _ SUPREME COURT ID #: __ AT'I'OI~Nh-y ~OR:DEFENDANT / Seal of the Cottrt ,2TI'IE COURT:~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY OSTEOPATHIC HOSP. 4300 LONDONDERRY RD. HARRISBURG, PA 17105 RE: 65950 JOHN p. BLESSING ANY AND ALL REPORTS INCLUDING PHYSICAL THERAPy REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Da~s Requested: up to and including the present. Subject: JOHN P. I]LESSING v 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security ~.. 199-54-7963 Date of Birth: 04-22-1962 SU10-318972 6 5 950 --LO2 CERTIFICATE PKL'P-EQUIsITE TO SEItvICE 0P A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN p. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO~ON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON j. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2001 MCS on behalf of JEFFERSON j. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272561 65950--L03 C 0 l~ll~l 0 I~I1 fl!: .~13_. ? It OF P E NN S '~'I~ V.~kl~I iA C 0 I.ll~I T y OF C ~ E R_i~AND IN THE MATTER OF: JOHN p. BLESSING ~VS- DIANE M. LIBERATORE COURT OF CO~ION PLEAs TERM, CASE NO: 01-1008 Op~I~_~I~p~,.~O..~S_E__i~- A SUBPOENA ~0 PRODUCE ~D~S THINGS F~ 40-- AND ..... -~- ~v ~uldg 4009.2~ [ Note: see enclosed list of locations ] ached to this notice. You have t~enty (20) days from the date listed belme in ~htch to file of re un.dersigned an objection t- --- - - cord and serv ....... waived or 16 .~ AL: .. ." LU= suopoena. If the ~ = -~-m r-ne . -- -~ vujecc~on ls msdD .k~ .. -- -----ty day notice Perio is c.oples of any reproduced records-.'._'"~_~ _r~_e~ su.opoena may be serwed.-Com~lde[~ th ---~ .e oruerea at your expense b ~.~e ,~t~.ached counsel card and returnin. ,.-- . .-- Y c~apietin. DATE: 07/24/2001 CC: J~FI~RSON J. SHIPHAN, ESQUIRE - 22740-1068 ~CS on behalf of ~tJ~llSON.$- SHIPHAN~ ESqUIRE Orney rot Dk~aSUaNT Any questions regarding ~s matter, contact · ~CS GROUP INC. 160114&Ri~T STR~T ~800 PHILADELPHIA, PA 19103 (215) 216-0900 DE02-159763 65950--001 LOC~TIOW LIST~ PAge: LOCATXONNM~ JOHN p. BLESSING VS DIANE M. LIBERATORE F{leNo.__ 01-i008 CIVIL ..... '~"' ~ LI: 4009 ~.22 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHic HOSPITAL (.~me o( Pez~on or ~'!:hin rove..--)..- I~) ddys after se~ice of t~s subpoena, .vou are ordered bv - mgm: . t~e Court to produce the following dOCuments or Yo~_mly de.~'er or m~] ]e~ble copies of the dOCUments or produce t ' . cei':mczte ~ ramph~ce, to the ~'"0/making this r*"uest ..... e. th. im~ re, q~ested by this sub,, of prep~rins the copies or producing the rhinp sO,J~ht If You f~j! to :reduce the dOCuments ar th/riSs required by th~s subp<)emd, wit. h.~ rwen~ (2a) divs ~ter seC'inS th~s s~.'~poeni mi), seek · couf~ order ¢ompelHn~ you to comply with ~.'-'ts scm'ice, the p~ry /'FILS SL'8?Ok-WA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: ADOR~$: 3~0 ~ S~., PO BX 1268 ~ISB~G, PA 17108 -- TELEPHON~ ~15_246_0900 SUPREME CO~ ID ~ A WO ~%'~' ~DE~T _ / Seal of the Cou~ ~-'----- (Eff. 7fg/-) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY OSTEOPATHIC HOSP. 4300 LONDONDERRY RD. HARRISBURG, PA 17105 RE: 65950 JOHN P. BLESSING ANY AND ALL DIAGNOSTIC TEST INCLUDING X-RAY REPORTS. Any and all X-Rays pertaining to patient. Date. s Requested: up to and includin, the re Subject: JOHN P. BLESSING ~. p sent. 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security//:. 199-54-7963 Date of Birth: 04-22-1962 SU10-318974 65950 --LO 3 CERTIFICATE PREREQUISITE TO SERVICE 0P A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN p. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO~ON PLEAS TERM, CASE NO: 01-1008 AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of__JEFFERSON j. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2001 MCS on behalf of J_EFFERSON j. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272562 65950 --LO 4 C 0 l~]l~IO I%F~r~:AL T H OF P E NN $1'7_. V.~I~ IA C OUI~ T Y OF IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATOKE COURT OF CO~40H PLEAS TERM, CASE NO: 01-1008 NOTICE OF INT=I~T TO SERVE A SUBPOENA TO PRODUCE DOCI1NRNTS AND · riliNGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: RICRARn A. SADLOCK, ESQUIRE MCS on behalf of J~a~SON J. SHIPMAN~ ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed bel~e in which to file of record and serve upon the ondersi~ned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena way be served. C~lete copies of any reproduced records may be ordered at your expense by com~leting the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 0712412001 CC: J1ff~KSON J. SHIR,~N, ESQOIRE - 227~0-1068 MCS on behalf of Ja~t~--KSON J. SHIPMAN~ ESQUIRE Attorney for DEfeNDAnT Any questions regarding this matter, contact TI:I.EI4CS GROUP INC. 1601MAc's'ET STR. K~T f800 PHILADELPHIA, PA 19103 (2~5) 246-0900 DE02-159763 65950--C01 >>> LOCATION LTST <<< PAGE: ~CO~DS eJ~U~ST~D OTHER MEDICAL X-RAY ONLY HKDICAL X-RAY ONLY I~DICAL RECORDS & xRAys t~DICAL RECORDS & XRAYS t~DICAL RECORDS & ]mAys )~DIC. AL RECORDS ~. XRAYS LOC&TTON ~ etnA'P. OPTIONS COJMBI~TY OSTEOPATHIC HOSP. COJ~fgl~TY OSTEOPATHIC HOSP. PT. HHACLK la~,T.TH HOSPITALS PINNACLE HEALTH HOSPITALS St~KKi.TON FAMILY I~DICINK ASSOC AUT.IHGTOH OIITHOPKD[C P~I~qSYLVANIA hSu~LO ASSOC. DE02-159763 ~_~,9_~0--C01 C~OMMON'WEALTH OF PENNSYLVANIA. c_OUNTY OF CUMBERLA.ND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 CIVIL TO: SUBPOENA TO PRODUCE DOCUM~---N-rs OR THINGq FOR DISCOVERY PURSUA_N-I' TO RULE 4009 CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH HOSPITAL (Name of Wi:bin m,~e..'~..- C~) days ~er se~ice of ~s su~p~ you ue order~ ~ ~e ~ to produce ~he following ~oc~ments or mings: ~ at MCS GROUP INC.t 1601 MARKET ST., #800, PHILA.,PA 19103 (Addrfls) You may deih-et or mail legible copies of the documents or produce ti'~b~s tqeq~aested by this subpoena, together with the certificate o.' rompliance, to the pa~y making this request at the &ddreu li.~ed above. You I~ve the tight to seek. in advaLnce, the .~monable cost of prepatin$ the copies ot producin$ the t'~inl~s 1£ you fail to ~oduce the documents ot things required by this subpc~,~m, witt-~in twenty (20) days al'ret its sen'ice, the parry. servin$ t~.is subpoena may seek · create order compelling you to comply with i*_ ' ' THIS SL'SPOENA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: NAME: .IIEFFF!~ RON .T ADDRF. S$: 320 MARKET ST., PO BX 1268 HA~ISBtmG. PA 17108 T£L£PHON=' 215-246-0900 SUPREME COURT ID #: ATTOR.N~' ~OR:DEFENDANT DAT5 goo Seal of the Com't (Eft. 719D EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH HOSPITALS 2601 NORTH 3RD STREET HARRISBURG, PA 17110 RE: 65950 JOHN P. BLESSING ANY AND ALL REPORTS INCLUDING PHYSICAL THERAPY REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject :JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-318976 6 5 950--L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE ~009.22 IN THE MATTER OF: JOHN P. BLESSING DIANE M. LIBERATORE COURT OF C0~940N PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272563 6 5 9 5 0 --LO5 CO~O~ ~'-AL TH OF PENN S I'I~V~I~ IA CO%~TY OF C%SW~ERL~D IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBE~ATOI~E C0~T OF ¢0~0N PLUS TE~, CASE NO: 01-1008 NOTICE OF Ilwr~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PUI~ TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JR~FRRSON J. SHIPMAN~ ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days rrm the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period ts waived or if no objection is made, then the subpoena may be served. C~aplete copies of any reproduced records may be ordered at your expense by completin$ the attached counsel card and returnin$ s-,~ to ~S or by contactin$ our local HCS office. DATE: 0712~12001 CC: ..~Fe~KSON J. SHIPMAN, ESQUIRE - 22740-1068 HCS on behalf of JEfferSON J. SHIPMAN~ EsquIRE Attorney for DEFENDANT Any questions regardin$ this matter, contact r~k MCS GROUP INC. 1601 MARKET STRKKT ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-159763 65950--C01 >>> LO~ATION LIST a~coaDs a~U~ST~D OSu~. X-RAY ONLY ~DI~AI. R~CORDS & ~AYS H~DIC, AL ~CO~S ~ ~YS ~I~ ~CO~S ~ ~YS ~I~ ~CO~S ~ ~YS LO~ATION N~14g OPTIONS COI~ONITY OSTEOPATHIC HOSP. CO~4UNITYOST~OP&THIC HOSP. p~ ~AL~ HOSPIT~S P~ ~ ~SPIT~S S~-TON ~Y ~IC~ ~S~ ~G~N OR. OPtIC P~S~V~ e~ ~S~. ~ & ~S~S, PT DE02-159763 65cJ'50--C01 .COMMONWEALTH OF PE~SYI. VANIA. COUNTY OF CUMBERL.-kND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 CIVIL TO: SUBPOENA TO PRODUCE DOCUM'~--'N-rs OR THING~ FOR DISCOVERY PURSUA.N'T TO RULE 4009 CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH HOSPITAL (Name of Pe~on or E.-ttt~) Within rwe.,-~..- (20) days af~er service of this subpoena, you are ordert~d by. the ~ to produce the following documents or :hangs: SEE ATTACHI~D at MCS GROUP INC. t 1601 MARKET ST., #800, PMILA.,PA 19103 You may dei~-~r or mail legible copies of the documents or produce thirds t~que~ted by t~s subp~n~ togemer with the cemficate ~ rompii~ce, to the p~ m~n~ this r~uest at the ad~ ~ a~e. You ~ve the right to see~ iff a~v~ce, ~e ~uona~le cost of prep~nS the copi~ or producing the t~ ~ 11 you fail to ~oduce the documents or thin~s required by this subl~m~, witl'.in twen~. (20) days after its sen'ice, the pa~y sen'inS ti~is subpoena ma)' st~k a court' order compelling you to comply with P_ THIS SUBPOENA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: NAME: .IE!~FI~RR('II~I .T.RI4TPMAIq. Eg{}~ ADDR~S: 320 ~ET ST., PO BX 1268 ~ISB~G. PA 17108 TELEPHON~ 215-246-0900 SUPR~M~ COb~T ID ~ A~O ~%'~' ~DEFE~T BY TI-rE COURT: ]~hOl~a4~'/~leric, C~v~ Division Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH HOSPITALS 2601 NORTH 3RD STREET HARRISBURG, PA 17110 RE: 65950 JOHN P. BLESSING ANY AND ALL DIAGNOSTIC TESTS INCLUDING X-RAY REPORTS. Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-318978 6 5 9 5 0 --LO5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF COMMON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272564 6 5 950--L0 6 C 0 l~]lvlO lq~41~%I~ T H OF PENN S 5V~e~I~ IA COUlqTY OF CI31~_]~]~I~LAND IN THE MATTER OF: JOEN P. BLESSING -VS- DIANE M. LIBERATOPd~ COU~T OF CO~9~ON PLEAS TERM, CASE NO: 01-1008 NOTICE OF I~RNTTO SERVE A SUBPORNATOPRODUCE DOCUNENTSAND 'miTNGS FOR DISCOvzRY p~--i~SUAHT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: RICHARD A. SADLOCI[, ESQUIRE MCS on behalf of JE~--aSON J. SHIPHAN~ ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed belme in which to file of record and serve upon the ondersi~ned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, than the subpoena may be served. Complete copies of any reproduced records may be ordered at your expanse by the attached counsel card and returning same to 14CS or by contacting our local HCS office. DATE: 0712~,12001 CC: J~-~SON J. SHTPMMI, ~SQUIRE - 227~.0-1068 HCS on behalf of JB~-~SON J. SHIPMAN, ESqUIRE Attorney for DE~DANT Any questions regarding this matter, contact THEN CS GROUP INC. 1601IiauE'~T STUNT ~800 PHILADKLPHIA, PA 19103 (215) 2~6-0900 DE02-159763 65950--C01 >~> LOCATION LT~T ~4:< parle: I ~CO~D$ ~$~D X-rAY ONLY I~DICAL X-rAY ONLY M~DICAL F~CORDS s; XRAYS M~DICAL RECOKD$ & X~AYS H~I)ICAL ~CORDS r- MEDICAl. R~COKDS & LOCATION Dg02-159763 _COMMON'WEALTH OF PE.'~$YLVANIA · ' COUNTY OF CUMBERI_~..ND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 CIVIL TO: SUBPOENA TO PRODUCE DO~-TS OR THING~ FOR DISCOVERY PURSUANT TO RULE 4009 CUSTODIAN OF RECOKDS FOR: STEELTON FAMILY MEDICINE ASSOCIATES (Name of Pe~on Within rwe..--~..- (~) days ~er se~ice of t~s subp~ you ~e ord~ ~ ~ ~n to produce ~he foilowlng ~uments or thing~ SEE A~AC~ MCS GRQUP INC. I 1601 MARKET ST., #800, PHILA. ,PA 19103 (Address) You may deih. er or mail legible copie~ of the documents or produce thirL~S l'~quested b.v t~s subp~ together with the ~e,ificate ~ compli~ce, to the p~ m~fl~ thi~ r~u~t at the ad~ ~ a~e. You ~%'e the right to see~ in advice, the ~uonable cost of prep~nS the copi~ ~ produ~n~ the ~n~ m~ you far to ?educe the documents or things required by this subpo4rm, withLn nven~ (20) days a~er its sen'ice, the pm'fy se~'ing t,%s sgbpoena may seek a court order compelling you to comp.])' with i~. THIS SL'BPO -ENA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: N.~uM~' .1~RRgnN .T. gI~T~94AN. RgQ, ADDR~S: 320 ~ET ST., PO BX 1268 ~ISB~G. PA 17108 TELEPHONR .215-246-0900 SUPR~M~ CO~ ID ~ A~O~N~' ~DEF~T 5ea~ of the Court (~ff. 7/9~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STEELTON FAMILY MEDICINE ASSOC 30 SOUTH FRONT STREET STEELTON, PA 17113 RE: 65950 JOHN P. BLESSING ANY AND ALL REPORTS, DIAGNOSTIC TESTS, INCLUDING PHYSICAL THERAPY REPORTS, AND X-RAY REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-318980 659 5 0 --LO6 CERTIFICATE PKEKEQUISITE TO SEIVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF C0~940N PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272565 6 5 950 --LO 7 C O~O ~I~AL TH OF PENN $ ~'I~V~IA CO~3~TY OF C~]~ESAND IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF C0~ON PLEAS TERM, CASE NO: 01-1008 NOTICE OF II~x~T TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVER][ PU~S~ TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: RICkeD A. SADLOCK, ESQUIRE MCS on behalf of JB~tRS0N J. SHIPMAN~ ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days £ron the date listed below in which to file of record and serve upon the ondersi~ned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. C.~Flete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning s..~ to MCS or by contacting our local MCS office. DATE: 0712~12001 CC: J~F~zKSON J. SBIPMAN, ESQUIRE - 22740-1068 MCS on behalf of JE~KSON J. SHIPMAN, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact T~Z l,~S GROUP INC. 1601 MAUlrRT STREET ~800 PHT_LAD~.,PHY. A, PA 19103 (215) 246-0900 DE02-159763 65950--(:01 LOCATION LIST <<< PA~K~ 1 LOCAT~ON ~ I~DICAL X-rAY ONLY MgDICAL x-rAY ONLY 14EDIt. AL RKCORDS & ~AYS MgDICAL I~gCO~DS & XRAYS MKDICAL RKCO~DS & X~AYS MKDICAL I~CORDS & I~AYS DN02-159763 6§950--C01 _COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLA_'WD JOHN P. BLESSING VS DIANE M. LIBERATORE ~le No. 01-1008 CIVIL TO: SUBPOENA TO PRODUCE DO~'TS OR THLNGS FOR DISCOVERY PURSUA.N'r TO RULE 4009 ~_2 CUSTODIAN OF RECORDS FOR: ARLINGTON ORTHOPEDIC CLINIC Whhin r~e..'~..- {20) days ~fter se~,,ice of this subpoez~, you ere ordered I~. the c~ur~ to product the following documents or thin,s: SEE ATTACHED ,~ . at MCS GROUP INC., 1601 MARKET ST., #800, PHILA. ,PA 19103 You may dali,.er or mail legible copie~ of the document~ or produce thin~ t~qat~ted by t~s sub~ together with the ce~i~cate ~ compliance, to the p~ m~nS this r~uflt at the Id~ advice, the ~uonable c~t of prep~nS the copifl or producin5 the ~n~ I( you fail m ?educe the documents or thinp required by this subpoena. ~ twen~ (20) day· after its service, the serving thi~ su~po*na may seek · court order compelling you to comp .fy with P_ THIS SL~PO~A WAS ISSUED AT THE REQUr~'T OF ~ POLLOWING PERSON: N.~uM~' .lEF~n.~nN .T..~g?I:~AN. ESO. ADDR~S: 320 ~ET ST., PO BX 1268 gA~RTSB~G. PA 17108 T~LEPHON~ 215-246-09~ SUPR~M~ CO~ ID ~ A~O~N~ ~DE~ D Al7.: Se~ofthe Court (-2ff. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ARLINGTON ORTHOPEDIC 805 SIR THOMAS COURT HARRISBURG, PA 17109 RE: 65950 JOHN P. BLESSING ANY AND ALL REPORTS, DIAGNOSTIC TEST, INCLUDING PHYSICAL THERAPY REPORTS AND X-RAY REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject :JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP I-III.L, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-318982 6 5 950 --LO 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF COMMON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272566 6 5 950--L08 C 0141~I0 BII~ -:~, T - T H OF PENN$1'I~ V~/~I IA C OI.ll~ T Y OF C ~ E PJ_.AND IN THE MATTER OF: JOHN P. BLESSING -V$- DIANE M. LIBERATORB COURT OF CO~ION PLEAS TERM, CASE NO: 01-1008 NOTICE OF II~TalIT TO SERVE A SUBP~A TO PRODUCE DOCUMENTS AND T~!MGS FOR DISCo¥1IKi i-OKSUANT TO RULE 4009.21 [ Note= see enclosed list of locations ] TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of jaFFK~S0N J. SHIPMAN~ ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed belme tn which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is ~ade, then the subpoena may be served. C~?lete copies of any reproduced records ~ay be ordered at your expense by c~leting the attached counsel card and returning sa~e to MCS or by contacting our local MCS office. DATE: 0712412001 CC: J~aaSON J. SHIM, ESQUIRE - 22740-1068 I,ICS on behalf of J~aaSON J. SHIPMAN~ ES~U'IR.K Attorney for DE----I,~IIDANT Any questions regardtn$ this matter, contact Tti.~MCS G~OUP INC. 1601 ~AU'k"KT STREET ~800 pHIT.AnI~.PHIA, PA 19103 (215) 246-0900 DE02-159763 65950--C01 ~ LOCATZON LIST u~CO~DS ~.~TKD OT~U~. NEDICAL X-rAY OHLY I~DXCAL X-~.! ONLY ~,~DI~-A1. R~CORDS & ~q~AyS ~DICAL RECORDS & XRAYS HEDICAL RECORDS ~ XRAYS I~DICAL RECORDS ~' XRAYS LOCATION ~AR OPTTONS CO~]T[TY OSTKOPATHZC HOSP. COt~4~WITY OSTEOPATHZC HOSP. P~NNACLK FflE~AT.T~ HOSPZTALS PXHNACLK HEALTH HOSPITALS S,[q~:~.TOH FAMTT.Y l~DZC~ ASSOC Ae~.INGTOH OETHOPRDIC p~NNSYLVAN/A k~ue, O ASSOC. MCrSuK/~ & ASSOCIATES, PT Dg02-~59763 COMMONWEALTH OF PENNSYLVANIA '. COUNTY OF CUMBERLAND JOHN P. BLESSING VS DIANE H. LIBERATOKE File No. 01-1008 CIVIL TO: SUBPOENA TO PRODUCE DO~'TS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009 ~.22 CUSTODIAN OF RECORDS FOR: PENNSYLVANIA NEUROLOGICAL ASSOCIATES, LTD. (.~am~ of Pe~on or ~'~i~) Within t-.ye.? (2D) days after service of tKis subpoena, you ~re ordered by the couz't to product the following documents or things: SEE ATTACHED =. MCS GROUP INC., 1601 MARKET ST., #800, PBILA. ,pA 19103 (AdcLr~l! You may deli'.'~ o~ mail les~ble copies of the documents or produce th.ir~; requested by t~s sub~n~ together with the ce~ificate ~ ~omp[i~ct, ~o the p~ m~nS this r~uest at the ad~ ~ a~e. You ~ve the right to see~ in advice, the ~uoflable cflt ~ prep~nS the copi~ oc producin~ the t~np ~L If you fa~l to .:'*.oduce the documents or th~n~s required by-this subpoer~, w'~t~-~'l rwen~ (20) days &fret its sec.'ice, the servi,$ this subpoena may mka cram* order compellifl$ you to ¢omp~ w~eh i~ THIS SUBPOENA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: NAM~. .IKF~n.~nN .T. ~nT~AN. EgO. ADOR~S: 320 ~gT ST., ~ BX 1268 ~RRTSB~G, PA 17108 TEL~PHON~ 215-246-0900 SUPR~ CO~ ID ~ A~O ~N~' ~DEF~T Seal of the Com't (Eft 7/g7 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENNSYLVANIA NEURO ASSOC. 108 LOWTHER STREET LEMOYNE, PA 17043 RE: 65950 JOHN P. BLESSING ANY AND ALL REPORTS AND DIAGNOSTIC TESTS INCLUDING PHYSICAL THERAPY REPORTS AND X-RAY REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dat.es Requested: up to and including the present. Subject :JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-318984 6 5 9 5 O--L08 CERTIFICATE PREREQUISITE TO SERVICE 0F A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF C0~940N PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON 3. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-272567 659 5 O--LO 9 CO~40~AL TH OF PENNS 5V~%I~IA CO%~TY OF C%~'4~aEP~LAND IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBEKATOt~E COU~T OF CO~ON PLEAS TE~M, CASE NO: 01-1008 NOTICE OF Ilw~.~/~T TO SERVE A SUBPO~ TO PRODUCE DOCI~rS ANn FOR DISCov=R¥ POIqSUANT TO RII~.~_ 4009.21 [ Note: see enclosed list of locations ] TO: ~ICHA~DA. SADLOCK, ESQUIHE HCS on behalf of JE~eaaSON J. SHIPMAN~ ESqUIP~ intends to serve a subpoena identical to the one that is attached to this notice. Yon have twenty (20) days frc~ the date listed below in which to file of record and serve upon the undersi~ned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena way be served. Complete copies of any reproduced records nay be ordered at your expense by cc~pletin$ the attached counsel card and return{.S sa~e to MCS or by contacting our local HCS office. DATE: 0712412001 CC: JEP~sIr, SON J. SHIPM~, ESQUIRE - 22740-1068 HCS on behalf of J~aKSON J. SHIPMAN~ ESqFIH~ Attorney for DE---F~NDA~T Any questions regard/rig th~s natter, contact T"'~MCS GROUP INC. 1601 MARKET ~800 PH/LADKLPHTA, PA 19103 (215) 246-0900 DE02-159763 65950--C01 RKCORDS REqUKSTED LOCATION LIST <<< LOCATION MKDICAL X-RAY ONLY HKDICAL X-RAY ONLY I~DICAL RECORDS & XRAYS ~DICAL RECORDS & XRAYS ~DICAL RECORDS & XRAYS H~DIC,~J., RKCORDS & XRAYS RKHAB OPTIONS C~I~E~ITY OSTEOPATIIIC HOSP. COJ~fONITY OSTEOPATHIC HOSP. PINNACLE HEALTH HOSPITALS PINNACLE HKALTH HOSPITALS STEKLTON FAHILy HEDICINE ASSOC Au~.iNGTON ORTHOPEDIC PKNNSYLVANY. A H,,UKO ASSOC. M[.,~u]f.H & ASSOCTATKS, PT DK02-159763 6-59.50--C01 COMMONWEALTH OF PE-'~SYLVANIA .... C~OUNT'Y OF CUMBERI...~.N~ - JOHN p. BLESSING VS DIANE H. LIBERATORE FHe No. - 01-1008 CIVIL TO: CUSTODIAN OF RECORDS FOR: MCCUEN & ASSOCIATES P~YSICAL THERAPy (Name o( Penon or ~.~n1) Within rwc..--?..- (20) days ,~er service of fl~s subpoena, you are ordered ~ the c~un to produce the following documents or rhin~ ~ [~C. 160~ ~ ~.~ ~800~ ~. ~A 19103 (Ad~s) ~ou reef de~.e ~ ~1 feeble copi~ of the d~menu or p~duce ~ ~u~ed bv ce.incite ~ compli~.c~ to ~Ae p~ ~nS chis r~ufl~ at the ~d~ ~ a~e. ~ou ~ve ~he right to Sff~ iff advmce, the w~oflable c~ of prep~fl! the copJ~ or produciflf the ~ I~ you f~l m ~oduce the d~umenm or t~np r~uired bv t~s sub~ sen'ins t~ sub~fla may ~k a c~ ord~ compiling you to comply ~ TI-tiS SL'SPO~4A WAS ISSUED AT THE REQUEST OF TI-rE FOLLOWING PERSON: ADDRESS: ,,,320 MAPaCET ST., PO BX 1268 HARRTSBIIRG, PA 171(}8 TEL £PHO.%'-'. 215-246-0900 SUPREME COUR~ ID e: Se~o~the Court BY COUWI2 A Civil Division (--ff. 7/9~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MCCUEN & ASSOCIATES, PT 240 GRANDVIEW AVENUE SUITE 5101 CAMP HILL, PA 17011 RE: 65950 JOHN P. BLESSING ANY AND ALL REPORTS AND DIAGNOSTIC TEST INCLUDING PHYSICAL THERAPY REPORTS AND X-RAY REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. sDuabt~s Req_uested: up to and including the present. ect :JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security/k. 199-54-7963 Date of Birth: 04-22-1962 SU10-318986 65950 --LO 9 CERTIFICATE pKEP~EQUISITE TO SE~¥ICE OP A SUBPOENA PUKSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE cOURT OF COMMON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 prio~ 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/18/2001 Attorney for DEFENDANT DEll-279716 65950--L10 C O1~]140 N~w-t~AL T H OF PENNSYLVANIA coU/~ TY OF CUlvIB E RLAND IN THE MATTER OF: JOHN P. BLESSING CoU~T OF COMMON PLEAS TERM, CASE NO: 01-100B -VS- DIANE M. LIBEEATORE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS ~ ---~-~FOR DISCOVERY PURSUANT TO~9'21 INSURANCE AETNA1 USHC ALLIED INSURANCE CO. INSURANCE TO: RICHARD A- SADLOCK, ESQUIRE HCS on behalf of JEFFEP~ON J- SHIPHAN, ESQUIRE intends to serwe a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning sa~ to MCS or by contacting our local HCS office. DATE: 0812712001 CC: JEFFERSON J. SHIPMAN, ESQUIKE - 22740-1068 14CS on behalf of JEFFerSON J. SHIPMAN, ESqUIKE Attorney for DE~NDANT Any questions regarding this matter, contact Tm MCS GROUP INC. 1601MARKET STREET ~8oo pH].LAI)~PHIA, PA 1910B (215) 246-0900 DE02-163057 65950--C01 COMMON~¥EALTH OF PE~5Y't-VANIA COUNTY OF CUMBERLA-ND. JOHN P. BLESSING VS DIA~E M. LIBERATORE File No. 01-1008 SUBPOENA TO PRODUCE DOCUMI~--N-r$ OR TI-lINGS FOR DISCOVERY PURSUA-N--f TO RULE 4009O-2~ RECO OS Fo : TNA/ S C Wkhin ~'e~' ~) days ~er sec'ice of t~s su~p~, yo~ ~e ord~ ~ ~e ~ to produce ~he foilowi~g ~oc~ments or min~s: ~GS GROUP ~G., 1601 ~E~ S~-, #800~ P~''P~ ~9103 Yo~ may dt~'~ or m~l le~ble copi~ of the d~umen~ or p~duce cemficate ~ compliance, to the p~ m~ng this requot at the advice, t~e ~monable cost of prep~n~ the (opi~ or producing the t~n~ m~t- If you f~l to ~oduce the d~uments or t~ngs required bv se~'ing :~s s~b~ena may s~k a c~ ord~ compelling you to comply TI-tiS SL'BPO~NA WAS ISSUED AT THE REQUEST OE'rJ-IE r-OLLOWING PERSON: NAME: jEFFERSON J. sHIPMAN, ESQ. ADORF.~5: 320 MARKET ST., PO BX 1268 HARRISBURG, PA 17108 _ TELE?HON=. 215-246-0900 SUPRE.ME COIJ~T IP #: - AT"r 0 R.N E'Y r-.o J~ DEFYN~ANT - SeaJ of the Co~'t EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: AETNA, INC. 151 FARMINGTON AVENUE I~W DOCUMENT CENTER HARTFORD, CT 06156 RE: 65950 JOHN P. BLESSING POLICY #: 199547963 Any and all claims files. Subject · J H 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Securi~ #: 199-54-7963 Date of Birth. 04-22-1962 Date of Loss: 05/06/1999 SU10-324926 65950--L10 CERTIFICATE pREREQUISITE TO SERVICE 0P A SUBPOENA pUP. suANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO~40N PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFEKSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/181200~ MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEl1-279717 6 5 9 5 0 --Lll C OtVi140 ~AL TH OF PENN sEVANIA coUNTY OF C 1314B EKLAND IN THE MATTER OF: JOHN P- BLESSING COURT OF COMMON PLEAS TERM, CASE NO: 01-1008 -VS- DIANE M. LIBERATORE NOTICE O~HiNGS FOR DISCOVERY pURSUANT INSURANCE AETNA] USHC INSURANCE ALLIED INSURANCE CO. TO: RICHARD A. sADLOCK, ESQUIR~ MCS on behalf of JEFFERSON J- SHIPHAN, ESQUIRE intends to serve a subpoena identical to the on---e that is attached to this ~otice. You have t~enty (20) days from the date listed belOv in vhich to file of record and serve upon the ondersi~ned an objection to the subpoena- If the tventy day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by cu~letinE the attached counsel card and returnins same to MCS or by contactin$ our local MCS office. DATE: 081271200~ CC: JEFFskSON J- SHIPMAN, ESQUIRE - 22740-1068 14CS on behalf of JEFFER. SON J- SHIPMMi, ESquirE_ Attorney for D~ANT Any questions resardins this matter, contact Tiffins GROUP INC. 1601MARI~T sTREET ~8oo palU~DEL~HIA, ~A 19103 (215) 246-0900 DE02-163057 65950--C01 COMMON'WEALTH OF pE~SYLVANIA COUNTY OF CUMBERL-~ND JOHN P. BLESSING VS DIANE M. LIBEKATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOCUM~'TS OR THINGS FOR DISCOVERY PURSUA..N-I' TO RULE 4009 ~..22 ~STODIAN OF REcoRDS FOR: ALLIED INSURANCE IN&m~ o~ Person m' -- w th n rwe..-~. · C~) days ~er sea, ice of t~s subp~, you ~* order~ ~ ~e ~un to produce the following d~uments or ~hings: at MCS GROUP INC., 1601 ~ET ST., #800, PHILA.,PA 19103 You may de~'~ or m~l feeble copi~ of the d~men~ or p~duce t~ ~u~ted by t~s sub.rtL together with the cemfica%e ~ compli~ce, to the p~ m~flg this rebuilt at the adM advice, the ~uonable cost of prep~ns the copifl oT producing the t~n~ . . ' if you f~l to ~oduce the d~umeflts or t~n~ required by t~s sub~ seC'ins c~s s~b~efla may stir a c~ ord~ compelling you to comply TI-lIS SUBPOENA WAS ISSUED AT THE REQUEST OF T'E-rE r-.OLLOWING PERSON: NAM~. JEFFERSON J. SHIPMAN, ESQ. ADDRESS: 320 MARKET ST., PO BX 1268 HARRISBURG, PA 17108 .. TELEPHON:-' 215-246-0900 SUPR~M£ COla'liT ll~ ~. Seal o~ the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALLIED INSURANCE CO. 70 WEST MICHIGAN AVE. BATI"LECREEK, MI 49017 RE: 65950 JOHN P. BLESSING TIG POLICY#: TKX 34407108 Any and all claims files. Dates Requested: up to and including the present. Subject: JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security/~. 199-54-7963 Date of Birth: 04-22-1962 Date of Loss: 05/06/1999 SU10-324618 65950--Lll PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( × ) for JURY trial at the next term of civil court. ( ) fo, r tr al without a jury. CAPTION OF CASE (entire caption must be stated in full) (check one) ( ) Assumpsit JOHN P. BLESSING, VS. DIANE M. LIBERATORE, VS. (Plaintiff) (Defendant) (x) ( ) Trespass Trespass (Motor Vehicle) (other) The trial list will be called on _ and 12/31/01 1/28/2002 Trials commence on 1/9/2002 Pretrials will be held on (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) NO. Civil 01-1008 19__ Indicate the attorney who will try case for the party who files this praecipe: Jefferson J. Shipman, Esquire, for the Defendant Richard A. Sadlock, Esqurie, Angino & Rovner, indicate trialcounselforotherpartiesifkn°wn: 4503 North Front St., Harrisburg, PA 17110, attorneys for Plaintiff This case is ready for trial. Date: _ 9/28/01 Signed:~ . [ ' Jeffe~'son J. Shipman Print Name: Attorney for: CERTIFICATE pREP~QUISITE TO SEIKVICE 0F A SUBPOENA pUP~UANT TO RULE ~009.22 IN THE MATTER OF: JOHN P. BLESSING oVS- DIANE M. LIBERATORE cOURT OF COMMON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/23/200~ ~/FERSONf~./SHiP~fAN, EsqUIRE Attorney for DEFENDANT DEll-287297 6 5 9 5 0 --L12 CO1,41,4OI~I-~TJ~ALTH OF PENNSYLVANIA coUNTY OF CT314BEKLAND IN THE MATTER OF: JOHN P. BLESSING -VS- COURT OF COMMON PLEAS TERM, CASE NO: 01-1008 DIANE M. LIBERATORE NOTICE OF im.,',~.mT TO SERVE A SUBP0~-NA TO PRODUCE DOCUMENTS AND THINGS FOR DISCoveRY PURSUANT TO RI~T.E 4009.21 BENYOUS BODY SHOP NAPA TRANSPORTATION TRANSCORPS ENTERPRISES, INC. UPS DR.STUARTHARTHAN DR. LJUBISA ST~VIC G~ HILL F~LY ~ CTR OTHER EI4PLOYHENT ~PLOYMENT ~PLOYHENT MEDICAL RECORDS & XBAYS MEDICAL RECORDS & X~AYS MEDICAL RECORDS & X~AYS TO: RICHARD A. SADLOCK, ESQUIRE HCS on behalf of JE~eZ~SON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this ,otice. You have t~nty (20) days from the date listed belo~ in ~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t~nty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 1010312001 CC: JEy~zKSON J. SHIPMAN, ESQUIRE - 227q0-1068 MCS on behalf of JE~EltSON J. SHIPMAN, ESQUIRE Attorney for DENE~uANT Any questions regarding this matter, contact TREHCS GROUP INC. 1601 MARKET STHEET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166414 65950--CO1 COMMON'WI~ALTH OF PE~SYLVANIA COUNTY OF CUMBERI_-%.ND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOCUM~'TS OR THINGS FOR DISCOVERY PURSUA_N-r TO RULE 4009 ~--2 CUSTODIAN OF RECORDS FOR: BENYOUS BODY SHOP (Name of Person or ~zi~) W thin n,,'e..'~..' (20) days a~ter sen'ice of this subpoena, you ~e ord~ ~ ~e ~un to produce the following documents or ~hings: SEE ATTACHED al MCS GROUP INC., 1601 MARKET ST., #800, PHILA. ,PA 19103 You may dcih'et or mail legible copie~ of the document~ or produce th~ ~q:[~ae~ted by this subpoena, together with the certificate of compliance, to the par~y makin$ this request at the add,'~l li~ed above. You have the right to seek. in adv~nceo the .-easonable cost of prep&tins the copi~ ot producing the thin~:~ If you f~l to ~oduce the documents or thingl requited by this subp~'~, within v~venry {201 days abet its sec.'ice, the patty, se~'in$ this s~.~poena may leek · court order compelling you to comply with THIS SUBPOENA WAS ISSUED AT THE REQUEST OF ~ r-OLLOWING PERSON: NAM~. JEFFERSON J. SHIPMAN~ ESq. ADDR~S: 320 MARKET ST., PO BX 1268 HARRISBURG, PA 17108 T£L~:pHON=_· 215-246-0900 SUPRE.M£ COUR'r ID ~: A~O~N~' ~ DEFE~T Seal of the Com't (Eff. 7/g7 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BENYOUS BODY SHOP 407 PLEASANT VIEW RD. NEW CUMBERLAND, PA 17170 RE: 65950 JOHN P. BLESSING ANY AND ALL REPAIR RECORDS, BILLS, STATEMENTS, ESTIMATES ON 1995 TOYOTA COROLLA DUE TO AN ACCIDENT ON 5/6/99 OWNED BY JOHN BLESSING Subject: JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security ~. 199-54-7963 Date of Birth: 04-22-1962 SU10-331144 6 5 9 5 0 --L1 2 CEItTTFICATE pKEREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE cOURT OF C0~940N PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/23/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-287298 6 5 9 5 0 --L1 3 COlV/lvION~J'[~ALTH OF PENNSYLVANIA COUNTY OF CL~I~IBERL~I~D IN THE MATTER OF: JOHN P. BLESSING -VS- COURT OF C0~i0N PLEAS TERM, CASE NO: 01-1008 DIANE M. LIBERATORE NOTICE OF INT~-I~ ~O SERVE A SUBPOm~& TO PRODUCE DOCUmENtS AND THINGS FOR DIScOV~lt~ MUIISUAI~ TO RUI~ 4009.21 BENYOUS BODY SHOP NAPA TRANSPORTATION TRANSCORPS ENTERPRISES, INC. UPS DR. STUART HA~TMAN DR. I.J~BISA STANKOVIC GREEN HILL FAHILY HEALTH CT~ OTHER ~PLOYMENT ~PLOYM~NT EMPLOYmeNT MEDICAL RECOHDS ~ X~AYS MEDICAL HECO~DS & X~AYS ~DICAL RECORDS ~ ]~AYS TO: RICHAHDA. SADLOCK, ESQUIRE HCS on behalf of J~SON J. SHIPMAN~ ESqUIHE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in ~nich to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by c-~pleting the attached counsel card and returning sa~e toM CS or by contacting our local MCS office. DATE: 1010312001 CC: JEPvEI~SON J. SHII~4&N, KSQU/~.E - 22740-1068 MCS on behalf of JEFem~SON J. SHIPMAN, ESQUIRE Attorney for DEI~,,~DAI~ Any questions regarding this matter, contact THEM CS GROUP INC. 1601 MARKET STeW~.T tS00 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166414 65950--C01 COMMON'WEALTH OF PE~SYLVANIA COUN'I'Y OF CUMBERLA.ND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOCUM~--N-FS OR THINGS FOR DISCOVERY PURSUA.N-f'TO RULE 40092.2 CUSTODIAN OF RECORDS FOR: NAPA TRANSPORTATION Wi:bin w..e..-..'~...- t~) days ~er se~'i~e of t~s s~. you ~e order~ ~ ~e ~ to ~roduct the foilowin~ documents or things: S~ ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 You may dei.h'rt or mail le~ble copie~ of the documents or produce t~ nn~:Iaested 'ny t~s sub~n~ together with the ce~i~ca~e ~ compliance, ro the p~ m~ng this r~uest at the ad~ ~ a~e. You ~ve the right to seek. ~n advice, the ~mona~le ~ost of prep~ng the copi~ or producing the ~n~ ~t. If you fail to .--.oduce the doc~lments or things required by this subpoena, wit.~.in nventy (20) days a~ter its sen'ice, the pa-fy seC'ins th. is s'~poena may seek a court order compelling you to comply with P. THIS 5L'BPOENA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: NAME: JEFFERSON J. SHIPMAN~ ESQ. ADDRESS: 320 MARKET ST., PO BX 1268 HARRISBURG, PA 17108 TELEPHONE: 215-2/,6-0900 SUPREME COU'P.T ID #: A'I-I'OR.NE'Y r. ol~ DEFENDANT DATE: Seal of the Cau, rt EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NAPA TRANSPORTATION 6866 BASHORE RD. MECHANICSBURG, PA 17055 RE: 65950 JOHN P. BLESSING Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: JOHN P. BLESSING 192S COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199.S4-7963 Date of Birth: 04-22-1962 SU10-331146 6 5 9 5 O--L1 3 CERTIFICATE PRERE0.UISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO~9{ON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10123/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-287299 65950--L14 CO~O~ALTH OF PENNSEVANIA cOUNTY OF CIR~iBERLAND IN THE MATTER OF: 30HN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO~fl40N PLEAS TERM, CASE NO: 01-1008 NOTICE OF INT,~t~T TO SERVE A SUBPOENA TO PRODUCE DOCUNENTS AND THINGS FOR DISCOVEI~ PURSUANT TO RULE 4009.21 BENYOUS BODY SHOP NAPA TRANSPORTATION TRANSCORPS ENTERPRISES, INC. UPS DH.STUARTHARTHAN DR. l,du~ISA ST&NROVIC GREEN HILL F~.~ILYHEALTH CTR OTHER ~4PLOYMENT EHPLOYHENT ~fl'LO¥14ENT MEDICAL RECORDS & X~AYS HEDICAL RECORDS & ][BAYS MEDICAL RECORDS & ]~AYS TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEeem~SON J. SHIPMAN, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~nty (20) days from the date listed belo~ in ~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t~nty day notice period is waived or if no objection is made, then the subpoena may be served. C-~plete copies of any reproduced records may be ordered at your expense by c~[etin$ the attached counsel card end returninE s-s-- to ~CS or by contactinB our local MCi office. DAYE: 1010312001 CC: J~y~KSON J. SHIPHAN, ESQUIRE - 22740-1068 MCS on behalf of J~sS0H J. SHIPMAN~ ESqUIRE Attorney for DEFENDANT Any questions regardin$ this matter, contact TIJ~ ~CS GROUP INC. 1601 MARKET STREET JS00 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166414 65950--C01 COMMONWEALTH OF PE~SYI. VANIA · COUNTY OF CUMBERLA.'qD JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOCUM~-FS OR THINGS FOR DISCOVERY PURSUA.N-r TO RULE 4009 ~.22 CUSTODIAN OF RECORDS FOR: TRANSCORPS ENTERPRISES, INC. Wkhin m,.'e.,--?..' ~) ~ays ~e~ sec'ice o~ r~s su~. you ~e order~ ~y ~e ~u~ ~o produc~ ~he foIl~wing documents or S~ ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 IAct~L-ts~) You may de~-er or mail feeble copie~ of the document~ or produce thin,~ t~q.~ae~ted by this subpoena, together with the certificate ~ compliance, to the pal'ty mak.in$ this request at the add~ IL~e~ above. You have the tight to seek, advance, t.he .'~uonable cost of preparing the copie~ ot produ¢in$ the thin~ ~ma~ht. If you fail to ..--.oduce the documents ot thin~ required by this sublmmerm, wit?,in twen~ (201 clays after its sec'ice the pa, rtv servin$ tais subpoena may se*k a cetu't order compelling you to comply with P_ THIS SUBPOENA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: NAM~- JEFFERSON J. SHIPMAN~ Esq. ADDRE~.~: 320 MARKET ST., PO BX 1268 HARRISBURG, PA 17108 TELEPMON=- 215-246-0q00 5UPRE.ME COURT ID ~ ATTOR.Nh-Y FOR: DEFENDANT iK~ot honota~rj ~.~,/~ vii Dt vision Seal of the Co~rt (--_ff. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TRANSCORPS ENTERPRISES, INC. 2601 HERR ST. HARRISBURG, PA 17103 RE: 65950 JOHN P. BLESSING Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject :JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-331148 6 5 9 5 0 --L1 4 CERTIFICATE PREREQUISITE TO SERVICE 0P A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF COMMON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuapt to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/23/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-287300 6 5 9 5 0 --L1 5 C 01~5~40 N%~r~:AL T H OF PENNSYLVANIA COUNTY OF ¢ Ul"IB E R/..~%.l~ D IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COU~T OF CO~ON PLEAS TERM, CASE NO: 01-1008 NOTICE OF II~TI~I~T TO SERVE A SUBPOENA TO PRODUCE D(~UI~T~S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 BENYOUS BODY SHOP NAPA TRANSPORTATION TRANSCORPS EI~TERPRISES, I~C. UPS DR.STUARTHARTMAN DR. I~U~ISA STANKOV~C GR~NHILL FAHILYHEALTHCTR OT- ~:.R EMPLOYMENT I~IPLOYM~NT EHPLOYMENT MEDICAL ~CODS ~ ~YS ~I~ ~CO~S & ~YS ~I~ ~CO~S & ~YS TO: RICHARD A. SAD$OCK, ESQUIRE MCS on behalf of J~ez~SON J. SHIPMAN, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~enty (20) days from the date listed belo~ in vhich to file of record and serve upon the undersiEned an objection to the subpoena. If the twenty day notice period is waived or if no objection is ---de, then the subpoena ~ay be served. Complete copies of any reproduced records may be ordered at your expense by c~letin$ the attached counsel card and returninE s.-~ to MCS or by contacting our local MGS office. DATE: 1010312001 CC: o-E;FffgASON J. SB/LR4A~, ESQUIRE - 22740-1068 tiCS on behalf of J~sRSON J. SHIPHAN, ESqUIRE Attorney for DE~ Any questions regarding this matter, contact TI~HCS GROUP INC. 1601 HARK~T STREET 18oo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166414 65950--C01 _COMMON'W'EALTH OF PE~SY'LVANIA COUNTY OF CUMBERL.A_ND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOCUM --~%'TS OR THINGS FOR DISCOVERY PURSUA. N-r TO RULE 4009 .r~ CUSTODIAN OF RECORDS FOR: UPS (N'ame a{ P~an or =..~=iry) '~.i:hin r*'e..'..':O...' ~) days ~e~ sec'ice of t~s subp~, you ~e or~er~ by ~e ~n to praduc~ the followim~ documems or :hings: $~ ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 You may delb,'rt or mail feeble copies of the document"~ or produce th.in~ re?~aested by this subpoena, toget.'~e? ~,ith the ce~ificate ~.' compliance, to the pa~'ty malciflg this request at the add..,'~ IL~e~:l above. You have the right :o seek. in advznceo the ~monable cost of preparing the copie~ ot producing the t~in~ ~t. If you fa~l to ?oduce the documet~ts or thin~ requited by this subp,oerm, witl'.in t~enty (20) days after its service. servin$ th~s s::~,poena may seek a couP' order compelling you to comply with THIS SL'BPOENA WAS ISSU~'D AT THE REQUEST OF T'tTE ~-OLLOWING PERSON: NAM~ JEFFERSON J. SHIPi'LL~, Esq. ADC}R.~$: 320 MARKET ST., PO BX 1268 HARRISBURG, PA 17108 TELEPHON=- 215-246-0q00 SUPRF..ME COURT ID ~ ATTOR.N~-Y FOR: DEFENDANT DATE: Seal of the Cotu't :--_ff. 7/9,-) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: UPS 359 EAST PARK DRIVE HARRISBURG, PA 17111 RE: 65950 JOHN P. BLESSING Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-331150 6 5 9 5 0 --L1 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF C0}940N PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 eCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/23/2001 eCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-287301 65950 --L16 COI~I~OI~w~ALTH OF PENNSYLVANIA COUNTY OF C%]~4BERLAND IN THE MATTER OF: JOHN P. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO}9~ON PLEAS TERM, CASE NO: 01-1008 NO~ICE OF I~'r~l~ ~O SERVE A SUBPOENA ~O PRODUCE DOCUMENTS AND THINGS FOR DISCOV~.R¥ PURSUAI~ TO RULE 4009.21 EENYOUS BODY SBOP NAPA T~NSPORTATION TRANSCORPS ENTERPHIsES, INC. UPS DH.STUARTHARTHAN DH. LJUBISA STAI~OVIC GRRRNHILLFAMILym~-AI.TIICTR OTBER EMPLOYMENT EHPLOYMENT EMPLOYMENT HEDICAL RECORDS & X~AYS HEDICAL RECORDS & XRAYS HEDICAL RECORDS & ~AYS TO: RIC~%~D A. SADLOCK, ESQUIRE HCS on behalf of J~aHSON J. SHIPMAN, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~nty (20) days fron the date listed belo~ in ~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t~nty day notice period is ~aived or if no objection is made, then the subpoena may be served. C~lete copies of any reproduced records may be ordered at your expense by c,-,.91etin8 the attached counsel card end retgrnin8 sa~e to MCS or b~ contactinS our local HCS office. DA~E: 1010312001 CC: JEFFerSON J. SHIPH&N, ESQUIRE - 22740-1068 MCS on behalf of JE~aKSON J. SHIPHAN, ESqUIRE Attorney for DEFENDANT Auy questions resardin~ ~his matter, t-mtact TH~14CS GROUP INC. 1601 MARKET STREET t800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166414 65950--C01 COMMONWEALTH OF PE~SY'LVANIA COUNTY OF CUMBERL-LND JOHN P. BLESSING VS DIA~NE M. LIBERATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOC'~ ."M -'-'-'-'-'-'-'-'-'~NWS OR THINGS FOR DISCOVERY PURSUA..\-r TO RULE 4009 °.22 CUSTODIAN OF RECORDS FOR: DR. STUART A. HARTMAN :nmOs: S~E ATTACHED a~ MCS GROUP INC., 1601 MARKET ST., :/800, PHILA.,PA 19103 You ..~av de~.'~ or mail feeble copies of the documents or produce t.h~":~q te~q~aested by this subpoena. :cge:.-,er wi:h the cer:if~c~'te ~.' :ompliance, to the patty, makin$ this request at the ad~'~ IL~e~ above. You have t~e risht advamce, t~e .~.uonable cost of pteparin$ the copies ot producin~ the thin~:s If you fzil tc ,--..o,~uce the document" or tl'dngs required by ti'ds sub.~ner, a. wit!"'Jn twenty. ("~1 ,~ays ad:st ils ser.':cs. :~e patty. se~'ing :~'~s s~ena may seek · cou~t order comps 1 ng you to comoly w~th P- THIS SL'BPOE'qA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMe- JEFFERSON J. SHIPMA~N, Esq. ADDRF.~.:: 320 bIARKET ST., PO BX 1268 ~RISBURG. PA 17108 TEL~PMON~ 2! ~-246-n°oo SUPREME CO~T ID ~: Seal of the Court, EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. STUART HARTMAN 2645 N.THIRD STREET SUITE 340 HARRISBURG, PA 17110 RE: 65950 JOHN P. BLESSING INCLUDING DIAGNOSTIC TEST RESULTS, INCLUDING PHYSICAL THERAPY REPORTS, X-RAY REPORTS, ER RECORDS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-$4-7963 Date of Birth: 04-22-1962 SU10-331152 65950--L16 CERTIFICATE PI~REqUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE ~009.22 IN THE MATTER OF: JOHN ?. BLESSING -VS- DIANE M. LIBERATORE COURT OF CO~40N PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 eCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/23/2001 eCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-287302 65950--L17 COI~II~IOMALTH OF PENNSYLVANIA COUNTY OF C%~I~IBERLAND IN THE MATTER OF: JOHN ?. BLESSING -VS- DIANE M. LIBERATORE C0UI~T OF C0~940N PLEAS TERM, CASE NO: 01-1008 NOTICE OF II~'f~NT TO SERV~ A SUBPOENA TO PRODUCE DOCUMENTS AND q~-~?NGS FOR DISCOVERY PURSUANT TO RULE 4009.21 B~NYOUS BODY SHOP NAPA TIM~SPORTATION TRANSCORPS ENTERPRISES, ~NC. UPS DR. STUART HAItT~AN DR. LJUBISA STAI~OVIC GR~N HILL PAI4~LY ~.~LTH CT~ OTHER EHPLOYI~NT EHPLOYHENT ~PLOYHE~T HEDICAL RECORDS & ~RA~S HEDICAL RECORDS & XRAYS ~DICAL RECORDS & xRAYS TO: RICHARD A. SM)LOCK, ESQUIRE MCS on behalf of JEF~sKSON J. SHIPMAN, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersisned an objection to the subpoena. If the tventy day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by cm?[etin8 the attached counsel card and returnin8 s-m- to MCS or by contactins our local MCS office. DATE: 1010312001 CC: J~Fe-,:*F, SON J. SHIP~4&N, ESQUIRE - 22740-1068 14CS on behalf of J~FFsaSON J. SHIPHAN, ESqUIRE Attorney for DEI~NDANT Any questions resarding this matter, contact THEM CS GROUP INC. 1601 MARKET STRUT ~800 PHILADKLPHIA, PA 19103 (21S) 246-0900 DE02-166414 65950--C01 _COMMON'W'EALTH OF PE.~SY'LVANIA COUNTY OF CUMBERL-%.ND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOC'L.-'vi~'-N-FS OR T"d. iNG$ FOR DISCOVERY PURSUA.N-I'TO RULE 4009?.22 CUSTODI.~N OF RECORDS EOR: DR. LJUBISA STANKOVIC Wi:him :'we..-~... ?o) days ~er se~'i~e of r~s subp~ma, you ~ or~er~ by the ~ to ~rodu~ :~e/c~!~w~g :~cum~n~s or :m~gs: SEE ATTACHED a~ MCS GROUP INC., 1601 MARKET ST., :~800, PHILA.,PA 19103 advice. :hr ~uoflabte cost of prep~ng the copi~ or ~roduc~flg the t~fl~ ~t. if vau faJI ra :-..oduce the documents or th.in~s required by ~s sub.~erm, w~.~.~m rwen~ (201 da,.s ad:e: ::s sen':ce, the pa-fy se~'in~ :~s i~oena may sesk a court order compelling you to comply with ~'- T'HIS SL'BPO.E.-NA WAS ISSUED AT 'I':~E REQL"E-~T OF "f"r.IE ~.OLLOWING PERSON: NAMe- JEFFERSON J. SHIPMAN, ESQ. ADDR~.~_~: 320 MARKET ST., PO BX i268 ~L~RRISBURG. PA 17108 TELEPMON_=: ~ 1 S~PR~ME COb~ ID ~: A~O~X~' ~ DEFE~T Seal o~ the Cau,.r: 7/9,") EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. LJUBISA STANKOVIC 797 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 65950 JOHN P. BLESSING INCLUDING DIAGNOSTIC TEST RESULTS, INCLUDING PHYSICAL THERAPY REPORTS, X-RAY REPORTS, AND ER RECORDS Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates ~e. quested: up to and including the present. Subject .JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-331154 65950--L17 CERTIFICATE P~EKEqUI$ITE TO SgI~VICE OF A SUBPOENA PURSUANT TO ~ULE ~009.22 IN THE MATTER OF: JOHN P. BLESSING DIANE M. -VS- LIBERATORE COURT OF COMMON PLEAS TERM, CASE NO: 01-1008 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE 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 which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/23/2001 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DEll-287303 6 5 9 5 0 --L 1-8 COb,II~IOS]-¥~I~ALTH OF PENNSYLVANIA COUNTY OF CtrI~BERLAND IN THE MATTER OF: JOHN P. BLESSING DIANE M. -VS- LIBEP. ATOKE C0U~T OF C0~40N PLEAS TEKM, CASE NO: 01-1008 NOTICE OF I~'J.'~AFf ~O SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAI~ TO RULE 4009.21 BKNYOUS BODY SHOP HAPA TRANSPOiKTATION TRANSCOR.PS ENTERPI~ISES, INC. UPS DE.STUART HARTJ4AN DR. LJUBISA STANKOVIC GREEN HILL PAMILY ~n~AI.TH CT~ OTHER EHPLOYMKNT ~4PLOYMENT BMPLOYHENT HEDI~.AT. R~CORDS & XRAYS HEDICAL RECORDS & XRAYS HEDICAL RECORDS & ~QLAYS TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JBFF~kSON J. SEIPHAN, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~nty (20) days from the datelisted belo~ in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Cu~ulete copies of any reproduced records may be ordered at your expense by cn~p. leting the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 1010312001 CC: J~=~=KSON J. SHIPMAN, KSQUIRK - 22740-1068 14CS on behalf of J~sKSON J. SHIPHAN, ESqUIRE Attorney for DEfeNDANT Any questions regarding this matter, contact TH~ HCS GROUP INC. 1601 14AKI~T STR~ J8oo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166414 65950--C01 COMMON'WEALTH OF PENNSYLVANIA COUNTY OF CUMBERL&.ND JOHN P. BLESSING VS DIANE M. LIBERATORE File No. 01-1008 TO: SUBPOENA TO PRODUCE DOCUM~,"FS OR TI-tINGS FOR DISCOVERY PURSUA.N-r TO RULE 400922 CUSTODIAN OF RECORDS FOR:GREEN HILL FAMILY HEALTH CENTER (Name o( Pev~on or -~'~i~'. ) Within rwe..-~... C2O) days ~ sewice of t~s subp~, you ~e order~ ~ ~e ~u~ to produce the following documents or ~hings: SEE ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 IAda,'~sl You may dei~'~ or mail le~ble copies of the documents or produce t~ reqquested by tl~is subpoena, together with the certificate o.' compliance, to the pa~y makJn$ this request at the add,-.~ IL~iKI above. You have the right to seek. in advance, the .'~uonable cost of preparing the copies or producing the thing If you fail to ?.oduce the documents or thin~ required by this subpoena, with. in twen~ (201 days a~ter its sen'ice, the party. ser~'ing this scbpoena may seek a cmu~ order compelling you to comply with P. TI-IlS SUBPOENA WAS ISSUED AT 'I'HE REQUEST OF ThE FOLLOWING PERSON: NAM~- JEFFERSON J. SHIPMANt ESq. ADDRF~S:320 MARKET ST., PO BX 1268 HARRISBURG, PA 17108 TELEPHON=-· 215-246-0q00 SUPREME COU~T ID ~ A'I'ro R.NE~' FOR: DEFENDANT Division Seal o~ the Court (=_ff. 7/97 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GREEN HILL FAMILY HEALTH CTR 503 BRIDGE STREET NEW CUMBERLAND, PA 17070 RE: 65950 JOHN P. BLESSING ANY AND ALL DIAGNOSTIC TEST RESULTS, INCLUDING PHYSICAL THERAPY REpoRT ER RECORDS, NOTE, ETC ..... Any and all records, correspondence, files and memorandums, handwritten notes, original X-Rays, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject :JOHN P. BLESSING 1925 COLUMBIA AVE, CAMP HILL, PA 17011 Social Security #: 199-54-7963 Date of Birth: 04-22-1962 SU10-331156 65950--L18 # 60LER JOHN P. BLESSLING, Plaintiff DIANE M. LIBERATORE, Defendant IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNS~V~IA . : CIVIL ACTION - LAW z~? No. 01-1008 CIVIL TERM PRETRIAL CONFERENCE A pretrial conference was held in the chambers of Judge Oler in the above-captioned case on Wednesday, January 9, 2002. Present on behalf of the Plaintiff was Richard A. Sadlock, Esquire. Present on behalf of the Defendant was Jefferson J. Shipman, Esquire. This is a negligence action for personal injuries arising out of a motor vehicle accident on May 6, 1999, on State Street in Lemoyne, Cumberland County, Pennsylvania, when Defendant's vehicle struck Plaintiff's vehicle from the rear at a traffic light. Liability for causing the accident is conceded on the part of Defendant. Defenses include lack of legal causation for injuries claimed by Plaintiff. This will be a jury trial in which each side will have four peremptory challenges, for a total of eight. The estimated duration of trial is two days. To the extent that any deposition testimony is to be shown or read to the jury and contains objections being pursued by counsel, counsel are directed to submit to the Court a copy of the transcript of the deposition in question with the areas of objection being pursued highlighted and with brief memoranda in support of their respective positions. Plaintiff has indicated that he will be filing a motion in limine to preclude testimony of an independent medical examiner in the person of Carl Ellenberger, Jr., a neurologist, as it relates to psychiatric or psychological conditions of the Plaintiff. Defendant has added to his list of witnesses Charles Smith, a UPS employee, and Dr. Albert Heck, without objection on the part of Plaintiff. With respect to settlement negotiations, Plaintiff has demanded $46,500.00, and Defendant has responded with a counteroffer of $5000.00. By the Court, Richard A. Sadlock, Esquire For the Plaintiff Jefferson J. Shipman, Esquire For the Defendant Court Administrator wcy John P. Blessing V Diane M. Liberatore IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1008 CIVIL TERM AND NOW, January 30, 2002, upon relation of the Court Administrator that this case cannot be reached this trial term due to the number of cases on the trial list, IT IS HEREBY ORDERED AND DIRECTED that this case be continued until the March 11, 2002 trial term. The Prothonotary is directed to relist this case for the March 11, 2002 trial term. Counsel are notified that they need not attend the Call of the List and no additional Pretrial Conference will be scheduled unless requested by either party. This case will be given preference and placed at the head of the list· By the Court, ~hard A. Sadlock, Esquire '~ For the Plaintiff /jefferson J. Shipman, Esqmre t/For the Defendant Court Administrator :ld 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN P. BLESSING, Plaintiff DIANE M. LIBERATORE, Defendant CIVIL ACTION - LAW NO. 01-1008 Civil Term JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff John P. Blessing intends to serve a subpoena identical to the one that is attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Date: February 6, 2002 I.D. No. 47281 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFF'S NOTICE OF INTENT TO SERVE SUBPOENA on the following via postage prepaid, first class United States mail, requested addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Date: February 6, 2002 242150 I\RAS\MLB JOHN P. BLESSING, Plaintiff V DIANE M. LIBERATORE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND cOUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01-1008 CIVIL TERM : JURY TRIAL DEMANDED VERDICT FORM 1. Was the Defendant's negligence a substantial factor in bringing Plaintiff's injuries? Yes (If you answer this question yes, answer the remaining question. If you answer this question no, the Plaintiff cannot recover and you should return to the courtroom.) 2. State the total amount of damages, if any, you find for the Plaintiff. Medical bills $ General $ Date: 2 · CA~E NO.: ~ ~- J~m~ # Name "' /~ Cfi~VR~O ~ ~---~-~ - Random No. 124 Smith, Debra 114 Souder, Donald L 117 Bilchak, Mary. J 1:26 Jones, Betty J 98 Baughman, Doris L 144-=-~ l~caston, Waiter2b-""~ ---'_n L)/ , -2087175804 -201M292207 -2006130900 -1973671472 -1809053382 -1751299246 -1555696727 -1481089375 125 C-'~,..~il, Tho.,., E ~ 127 Price, William F HI 120 Jones, Llewellyn B 132 Duncan, Scott A 123 Walker, Cynthia M 99 Ream, Ronald V 107 Brion, Donald L 133 Lake, Walter A Jr 122 Strahosky, Carol J 96 Pasquaratte, Kathleen A 113 Enloe, Marvin N 118 Berg, Larry A 134 Earo, David W 102 Lawyer, Rebecca 97 Gons, Myra F 112 Peechatka, Walter N 110 Li~gitt, Tamy J 121 Wolf, Beverly M -1301367755 -1294866069 -1163607363 -1077167624 -9988739mi -963273617 -902780972 -378164554 -295001566 278453799 307624005 350817275 502534374 - 1083636675 1105971639 1216854835 1228281564 1619953151 1652257608 1672300622 1702534432 1709473945 Jefferson J. Shipman, Esquire I.D. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendant JOHN P. BLESSING, : IN THE COURT OF COMMON PLEAS OF Plaintiff VS. DIAaNE M. LIBERATORE, Defendant CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTON - I2tW : : NO. 01-1008 Civil Term : JURY TRIAL DEMANDED PRAECIP~ TO THE PROTHONTOARY: PLEASE enter judgment in favor of the Defendant, Diane Liberatore, based upon the verdict of March 12, 2002. DATE: 77328.1 GOLDBERG, ~TZMAN & SHIPMAN, P.C. Jef~e~ j. §hi,an, Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on March 29, 2002: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiff 60049.1 GOLDBERG, KATZMAN & SHIPMAN, P.C. ~B~Jef~n J. S~i~man, AttOrney I.D. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant Esquire