Loading...
HomeMy WebLinkAbout01-1025MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFFS SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w 9 South Humer Street Enola, PA 17025, Plaintiffs AARON DAVIDSON 4967 Lincoln Road Macedon, NY 14502, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en la corte. Si usted defenderse de estas demandas expuestas en law paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, ia corte tomara medidas y puede continuer ia demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decodor a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO T[ENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA D1RECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MORGAN & MORGAN, P.C, BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFFS SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w 9 South Humer Street Enola, PA 17025, Plaintiffs AARON DAVIDSON 4967 Lincoln Road Macedon, NY 14502, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. tv/- : ' CIVIL ACTION - LAW : : JURY TRIAL DEMANDED : : : COMPLAINT Plaintiffs, by and through their attorneys, Morgan & Morgan, P.C., hereby complain against Defendant and aver as follows: l. Plaintiffs are husband and wife residing at the above address. 2. Defendant is an adult individual residing at the above address. 3. On or about February 23, 1999, Plaintiff Sandra Williams was stopped in her motor vehicle on Trindle Road in Cumberland County, PA, when she was struck in the rear by a vehicle operated by Defendant. 4. As a result of the collision, wife Plaintiff suffered injuries and damages as are more fully set forth below. 5. The aforesaid collision was due to the negligence of Defendant, including: A. Traveling at an unsafe speed; risk of harm; distance ahead. B. Failing to keep a proper lookout; C. Failing to keep his vehicle under proper control; D. Failing to warn Plaintiff of an unreasonable E. Striking the rear of Plaintiff's vehicle; F. Failing to stop his vehicle in the assured clear COUNT I SANDRA D. WILLIAMS v. DEFENDANT 6. Plaintiff incorporates herein by reference the allegations of paragraphs 1 through 5 as if fully set forth at length. 7. As a result of Defendant's negligence, Plaintiff suffered severe injuries to her nerves, bones, muscles, joints and fascia, pain and suffering, mental and emotional distress, which are continuing. 8. As a result of her injuries, Plaintiff incurred medical bills for care, treatment and rehabilitation, lost earnings and/or earning capacity, and suffered loss of life's pleasures and diminution of daily activities, which are continuing. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. COUNT II THOMAS WILLIAMS v. DEFENDANT 9. Plaintiff incorporates herein by reference the allegations of paragraphs 1 through 5 as if fully set forth at length. 10. As a result of Defendant's negligence, Plaintiff has suffered the loss of consortium, society, services and companionship of his wife, Sandra Williams, which is continuing. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. DATED: February ~?~3, 2001 MORGAN & MORGAN, P.C. $co uire A~tt6ri~eys for Plaintiffs VERIFICATION Sandra W'flliams states that she is Plaintiffin this matter, and that the statements made in the foregoing Complaint are tree and correct to the best of her knowledge, information and belief She understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. S ah~dra Williams FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnm Street Lancaster, PA 17602 (717) 39%9444 Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS Plaintiffs AARON DAVIDSON Defendant No.: 01-1025 JURY TRIAL DEMANDED PRAEC1PE TO THE PROTHONOTARY: Please enter the appearance of D, Holbrook Duer, Esquire, and Flanagan and Benner on behalf of Defendant Aaron Davidson in the above-captioned matter. All papers may be served at 150 East Chestnut Street, Lancaster, PA 17602. I hereby certify that I have this day caused a copy of the foregoing to be served upon opposing counsel by furst class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 By: I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and : THOMAS WILLIAMS : Pla'mtiffs : V, : AARON DAVIDSON : Defendant : No.: 01-1025 JURY TRIAL DEMANDED DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFFS' COMPLAINT 1. Denied. Answering Defendant is without knowledge or information sufficient to form a belief as to the U:uth of this averment. Admitted. 3. Admitted in part and den'led in part. It is admitted that an irapact occurred between the front of a vehicle operated by Defendant and the rear of a vehicle operated by Plaintiff on the date and at the place alleged. The remaining averments of this paragraph are denied pursuant to Pa.R.C.P. 1029. 4.-10. Denied pursuant to Pa.R.C.P. 1029. WHEREFORE, Answering Defendant requests that judgment be entered in his favor against all other parties to this action. NEW MATTER 11. Answering Defendant incorporates herein by reference the averments contained in paragraphs 1 through 10 of the foregoing Answer as if fully set forth herein. The Plaintiffs may have fa'fled to state a cause of action upon which relief can be 12. granted. 13. this action. 14. 15. The applicable statute of limitations may have expired prior to the institution of Answering Defendant was not negligent. Any acts or omissions of answering Defendant alleged to constitute negligence may not be substantial causes or factors of the subject incident and/or may not have resulted in the injuries and/or losses alleged by the Plaintiffs. 16. The incident and/or damages described in Plaintiffs' complaint may have been caused or contributed to by the Plaintiffs. 17. The negligent acts or omissions of other individuals and/or entities may have constituted intervening superseding causes of the damages and/or injuries alleged to have been sustained by the Plaintiffs. 18. Plaintiffs may have assumed the risk, and been contributorily negligent. 19. The incident, injuries and/or damages alleged to have been sustained by the Plaintiffs may not have been prox'maately caused by Answering Defendant. 20. Plaintiffs may not have properly mitigated their damages. 21. Plaintiffs may have selected or may be otherwise bound by the limited tort option pursuant to 75 Pa.C.S.A. §1705 and is therefore, barred from recovery of non-economic damages because Plaintiffs' injuries, if any, do not constitute a serious injury as that term is clef'reed in 75 Pa.C.S.A. §1702. 22. Some or all of Plaintiffs' damages may be barred by the provisions of 75 Pa.C.S.A. §1720 and 1722. WHEREFORE, Answering Defendant respectfully requests that this Court grant judgment in his favor and against all other parties to this action. FLANAGAN & BENNER D.MqolbrGok Duer, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson VERIFICATION I, D. Holbrook Duer, Esquire, hereby verify that I am the attorney for the Defendant Mark Krebs in the foregoing action and that the averments of the attached Defendant's Answer and New Matter to Plaintiffs' Complaint are true and correct to the best of my knowledge, information and belief. This Defendant's Answer and New Matter to Plaintiffs' Complaint is verified by counsel to permit timely filing in compliance with applicable roles of civil procedure. I understand that I am subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities for any false statements made herein. D. ~Esquire CERTIFICATE OF SERVICE I, D. Holbrook Duer, Esquire, hereby certify that I have this day served a true and correct copy of the foregoing documem on the following person and in the manner indicated below: First class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 By: FLANAGAN & BENNER DVHolbr6~ok Duer, Esquire I.D. No. 57324 150 East Chesmut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS Plaimiffs AARON DAVIDSON Defendant No.: 01-1025 JURY TRIAL DEMANDED DEFENDANT'S OBJECTIONS TO PLAINTIFFS' INTERROGATORIES AND DOCUMENT REOUESTS Iii INTERROGATORIES A. Beyond the scope of permissible discovery under Pa.R.C.P.4003.3: None. B. Beyond the scope of permissible discovery pursuant to Pa.R.C.P.4003.5: 22 (d) C. Beyond the scope of permissible discovery under Pa.R.C.P.4003.1 and 4011: None. REQUEST FOR PRODUCTION OF DOCUMENTS A. Beyond the scope of permissible discovery under Pa.R.C.P.4003.3: 5 B. Beyond the scope of permissible discovery pursuant to Pa.R.C.P.4003.5: 5 D. Beyond the scope of permissible discovery under Pa.R.C.P.4003.1 and 4011: None. Date: By: I.D. No. 57324 150 East Chesmut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson CERTIFICATE OF SERVICE I, D. Holbrook Duer, Esquire, hereby certify that I have this day served a true and correct copy of the foregoing documem on the following person and in the manner indicated below: First class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 I.D. No. 57324 150 East Chesmut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson MORGAN & MORGAN, P.£. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFFS SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w Plaintiffs v. AARON DAVIDSON Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : : NO. 01-1025 Civil : : CIVIL ACTION - LAW : : JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO NEW MATTER Plaintiffs, through their attorneys Morgan & Morgan, P.C., hereby responds to New Matter of Defendant, and avers as follows: 11-22. The allegations of these paragraphs are denied as conclusions of law to which no answer is required. WHEREFORE, Plaintiffs request that New Matter be dismissed and judgment entered in their favor. MORGAN & MORGAN, P.C. DATED: March 13, 2001 Attorneys for Plaintiffs VERIFICATION Scott W. Morgan, Esquire states that he is counsel of record for Plaintiffs in the within action, is authorized to take this Verification on their behalf, and that the statements made in the foregoing Keply to New Matter are true and correct to the best of his knowledge, information and belief. He understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. CERTIFICATE OF SERVICE I, Michele E. Neff, Legal Assistant for Morgan & Morgan, P.C., hereby certify that service of the original within Plaintiffs' Reply to New Matter was made on this I~4~h~ day of March, 2001, to the persons below named, by First Class United States Mail, postage prepaid. D. Holbrook Duer, Esquire FLANAGAN and BENNER 150 East Chestnut Street Lancaster, PA 17602 MORGAN & MORGAN, P.C. Miche[e E. Neff, Legal A~st~[hnt to Scott W. Morgan, Esquire 120 South Street Harrisburg, PA 17101-1210 (717) 236-7959 Attorneys for Plaintiffs FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-??.~. Attorneys for Defendant Aaron Davidson lan THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS Plaintiffs AARON DAVIDSON Defendant No.: 01-I025 JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification of Aaron Davidson for the Verification of D. Holbrook Duer, Esquire attached to Defendant's Answer and New Matter to Plaintiffs' Complaint previously filed with the court. By: I.D. No. 57324 150 East Chesmut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson CERTIFICATE OF SERVICE I, D. Holbrook Duer, Esquire, hereby certify that I have this day served a true and correct copy of the foregoing document on the following person and in the manner indicated below: First class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 D. Holbrb~ok Duer, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson VERIFICATION I, Aaron Davidson, hereby verify that I am the Defendant in the foregoing action and that the averments contained in Defendant's Answer and New Matter to Plaintiffs' Complaint are true and correct to the best of my knowledge, information and belief. To the extent that the averments are based on an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities for any false statements made herein. Aaron Davidson FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS, Plaintiffs No.: 01-1025 AARON DAVIDSON, Defendant JASON ALAN BRANDT, Additional Defendant JURY TRIALDEMANDED PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification of Aaron Davidson for the Verification of D. Holbrook Duer, Esquire attached to Defendant's Joinder Complaint previously filed with the court in the above-referenced matter. .~Holbr~ook~Duer, EsqUire I.D. No. 57324 Attorney for Defendant Davidson VERIFICATION I, Aaron Davidson, hereby verify that I am the Defendant in the foregoing action and that the averments contained in the foregoing Joinder Complaint are true and correct to the best of my knowledge, information and belief. To the extent that the averments are based on an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities for any false statements made herein. AARON DAVIDSON CERTIFICATE OF SERVICE I, D. Holbrook Duer, Esquire, hereby certify that I have this day served a true and correct copy of the foregoing document on the following person and in the manner indicated below: First class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 Date: ~/}~/0' By: qNER uir~"' I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 Attorney for Defendant Davidson FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w 9 South Humer Street Enola, PA 17025 Plaintiffs No.: 01-1025 AARON DAVIDSON, 4967 Lincoln Road Macedon, NY 14502 Defendant JASON ALAN BRANDT, 201 South 3rd Street Steelton, PA 17113 Additional Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a wdtten appearance personally or by attorney and filing in wdting with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, District Court Administrator Lancaster County Courthouse 50 North Duke Street, P.O. Box 3480 Lancaster, Pennsylvania 17603-1881 (717) 299-8041 FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Defendant Aaron Oavidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w 9 South Humer Street Enola, PA 17025 Plaintiffs No.: 01-1025 AARON DAVIDSON, 4967 Lincoln Road Macedon, NY 14502 Defendant JASON ALAN BRANDT, 201 South 3rd Street Steelton, PA 17113 Additional Defendant JURY TRIAL DEMANDED AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escfita oen persona o con un abogado y entegas a la coke en forrna escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, ia corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiem que usted compla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFIClENTE DE PAGAR TAL SERVlCIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIClNA CUYA DIRECTION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUlR ASlSTENClA LEGAL. District Court Administrator Lancaster County Courthouse 50 North Duke Street, P.O. Box 3480 Lancaster, Pennsylvania 17603-1881 (717) 299-8041 FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w 9 South Humer Street Enola, PA 17025 Plaintiffs No.: 01-1025 AARON DAVIDSON, 4967 Lincoln Road Macedon, NY 14502 Defendant JASON ALAN BRANDT, 201 South 3rd Street Steelton, PA 17113 Additional Defendant JURY TRIAL DEMANDED JOINDER COMPLAINT 1. Plaintiff filed the Complaint in this matter on or about February 20, 2001, a true and correct copy of which is attached hereto as Exhibit A. 2. The Complaint claims personal injuries adsing out of a motor vehicle accident which occurred on February 23, 1999, as more fully set forth in the Complaint. 3. A true and correct copy of Defendant's Answer to Plaintiff's Complaint is attached hereto as Exhibit B. 4. The motor vehicle accident complained of in Plaintiff's Complaint was caused in whole or in part by the negligence of Additional Defendant Jason Alan Brandt, an adult individual residing at the address set forth in the caption, in failing to maintain proper control of his vehicle, causing Defendant's vehicle, in whole or part, to collide with Plaintiff's vehicle. 5. Defendant Davidson joins Jason Alan Brandt as an Additional Defendant in this matter and avers that he is solely liable to Plaintiff, liable over to Plaintiff, jointly and severally liable with Defendant Davidson to Plaintiffs Williams and/or liable to Defendant Davidson for contribution and/or indemnity for any amounts for which Defendant Davidson is caused to pay as a result of this action. WHEREFORE, Defendant Aaron Davidson respectfully requests that judgment be entered against Additional Defendant Jason Alan Brandt for all those sums of money which Defendant Davidson may be caused to pay as a result of this action. Date: '~/~/bJ By: ~ENNER I. D. No.: 57324 Attorney for Defendant Davidson Exhibit A MORGAN & MORGAN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATTORNEYS FOR PLAINTIFFS SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w 9 South Humer Sa'eet Enola, PA 17025, Plaintiffs AARON DAVIDSON 4967 Lincoln Road Macedon, NY 14502, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 01-1025 Civil CIVIL ACTION ~ LAW JURY TRIAL DEMANDED COMPLAINT Plaintiffs, by and through their attorneys, Morgan & Morgan, P.C., hereby complain against Defendant and aver as follows: 1. Plaintiffs axe husband and wife residing at the above address. 2. Defendant is an adult individual residing at the above address. 3. On or about February 23, 1999, Plaintiff Sandra Williams was stopped in her motor vehicle on Trindle Road in Cumberland County, PA, when she was struck in the rear by a vehicle operated by Defendant. 4. As a result of the collision, wife Plaintiff suffered injuries and damages as are more fully set forth below. 5. The aforesaid collision was due to the negligence of Defendant, including: A. Traveling at an unsafe speed; risk of harm; distance ahead. B. Failing to keep a proper lookout; C. Failing to keep his vehicle under proper control; D. Failing to warn Plaintiff of an unreasonable E. Striking the rear of Plaintiff's vehicle; F. Failing to stop his vehicle in the assured clear COUNT I SANDRA D. WILLIAMS v. DEFENDANT 6. Plaintiff incorporates herein by reference the allegations of paragraphs 1 through 5 as if fully set forth at length. 7. As a result of Defendant's negligence, Plaintiff suffered severe injuries to her nerves, bones, muscles, joints and fascia, pain and suffering, mental and emotional distress, which are continuing. 8. As a result of her injuries, Plaintiff incurred medical bills for care, treatment and rehabilitation, lost earnings and/or earning capacity, and suffered loss of life's pleasures and diminution of daily activities, which are continuing. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. COUNT II THOMAS WILLIAMS v. DEFENDANT 9. Plaintiff incorporates herein by reference the allegations of paragraphs 1 through 5 as if fully set forth at length. 10. As a result of Defendant's negligence, Plaintiff has suffered the loss of consortium, society, services and companionship of his wife, Sandra Williams, which is continuing. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $25,000.00, exclusive of interest, costs and delay damages. DATED: February ~, 2001 MORGAN & MORGAN, P.C. By / ....'~~' Scott ~. Morgan, l~squire tr r eys for VERIFICATION Sandra William~ states that she is Plaintiff in this matter, and that the statements made in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. She understands that the statements in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. Exhibit B FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Vq~nda~: AnrOnDn~on .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW SANDRA D. WILLIAMS and . ~,~ THOMAS WILLIAMS : ~ No.: 01-1025 ~ Plaintiffs : : V. : : AARON DAVIDSON : Defendant : JURY TRIAL DEMANDED DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFFS' COMPLAINT 1. Denied. Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of this averment. 2. Admitted. 3. Admitted in part and denied in part. It is admitted that an impact occurred between the front of a vehicle operated by Defendant and the rear of a vehicle operated by Plaintiff on the date and at the place alleged. The remaining averments of this paragraph are denied pursuant to Pa.R.C.P. 1029. 4.-10. Denied pursuant to Pa.R.C.P. 1029. WHEREFORE, Answering Defendant requests that judgment be entered in his favor against all other parties to this action. NEW MATTER 11. Answering Defendant incorporates herein by reference the averments contained in paragraphs 1 through 10 of the foregoing Answer as if fully set forth herein. The Plaintiffs may have failed to state a cause of action upon which relief can be 12. granted. 13. this action. 14. 15. The applicable statute of limitations may have expired prior to the institution of Answering Defendant was not negligent. Any acts or omissions of answering Defendant alleged to constitute negligence may not be substantial causes or factors of the subject incident and/or may not have resulted in the injuries and/or losses alleged by the Plaintiffs. 16. The incident and/or damages described in Plaintiffs' complaint may have been caused or contributed to by the Plaintiffs. 17. The negligent acts or omissions of other individuals and/or entities may have comtimted intervening superseding causes of the damages and/or injuries alleged to have been sustained by the Plaintiffs. 18. Plaintiffs may have assumed the risk, and been contributorily negligent. 19. The incident, injuries and/or damages alleged to have been sustained by the Plaintiffs may not have been proximately caused by Answering Defendant. 20. Plaintiffs may not have properly mitigated their damages. 21. Plaintiffs may have selected or may be otherwise bound by the limited tort option pursuant to 75 Pa.C.S.A. §1705 and is therefore, barred from recovery of non-economic damages because Plaintiffs' injuries, if any, do not constitute a serious injury as that term is defined in 75 Pa.C.S.A. §1702. 22. Some or all of Plaintiffs' damages may be barred by the provisions of 75 Pa.C.S.A. §1720 and 1722. WHEREFORE, Answering Defendant respectfully requests that this Court grant judgment in his favor and against all other parties to tiffs action. FLANAGAN & BENNER D.~olbr6'ok Duer, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson VERIFICATION I, D. Hoibrook Duer, Esquire, hereby verify that I am the attorney for the Defendant Mark Krebs in the foregoing action and that the averments of the at~ached Defendant's Answer and New Matter to Plaintiffs' Complaint are true and correct to the best of my knowledge, information and belief. This Defendant's Answer and New Matter to Plaintiffs' Complaint is verified by counsel to permit timely filing in compliance with applicable rules of civil procedure. I understand that I am subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities for any false statements made herein. D. quire CERTIFICATE OF SERVICE I, D. Holbrook Duer, Esquire, hereby certify that I have this day served a true and correct copy of the foregoing document on the following person and in the manner indicated below: First class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 By: FLANAGAN & BENNER D.~olbr~ok Duer, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson VERIFICATION I, D. Holbrook Duer, Esquire, hereby verify that I am the attorney for the Defendant in the foregoing action and that the averments of the attached Joinder Complaint are true and correct to the best of my knowledge, information and belief. This Joinder Complaint is verified by counsel to permit timely filing in compliance with applicable rules of civil procedure. I understand that I am subject to the penalties of 18 Pa.C.S.§4904, relating to unswom falsification to authorities for any false statements made herein. Date: ~_~}~.O-)J(~ D.~QUIRE CERTIFICATE OF SERVICE I, D. Holbrook Duer, Esquire, hereby certify that I have this day served a true and correct copy of the foregoing document on the following person and in the manner indicated below: First Class Mail, Postage Pro-Paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 Date: 5/~.~/ ~1 By: FLANAGAN and BENNER I. D. No.: 57324 Attorney for Defendant Davidson SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-01025 P COMMONWEALTH OF PENNSYLVanIA: COUNTY OF CUMBERLAND WILLIAMS SANDP~A D ET AL VS DAVIDSON AARON R. Thomas Kline duly sworn according to law, and inquiry for the within named A~DD'L DEFENDANT BR3LNDT JASON ALAN but was unable to locate Him deputized the sheriff of DAUPHIN , Sheriff or Deputy Sheriff says, that he made a diligent , to wit: in his bailiwick. County, serve the within COMPLAINT & NOTICE who being search and He therefore Pennsylvania, to On April 16th , 2001 attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep. Dauphin Co 26.75 .00 63.75 04/i6/200i FLANAGAN & BENNER Sworn and subscribed to before me this ~ 3~ day of ~'~ ~ I A.D. Prothonot~r[z ' this office was in receipt of the Sheriff of CUmberland County Sheriff, s Costs: $26.75 PD 03/29/2001 RCPT NO 148137 MGV ~ The Court of Common Pteas of Cumberland County, Pennsylvania Sanflra D. williams, et. al. Aaron Davidson, et. al. Serve: Jason Alan Brandt No. 01-1025 Civil ~JOW, 3 / 27 / 01 ., 20 O ~, I, SHERIFF OF CUMBERLAND COIDNT¥, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintifr2 gher~ff of Cumberland County, PA ~,TO'vV~ within Affidavit of Ser~4ce ,20 ,at o'clock served the t~y handi2g to a and made tmown to copy of the ofigSnal ~0 flrl. SWers ~ the contents ~ereof. Sheriff of CounW, PA Sworn and subsc~Sbed before me th/s __ day of ,2O COSTS SERVICE M1-LEAOE AFF_TDAVIT SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w, Plaintiffs v. AARON DAVIDSON, Defendant V. JASON ALAN BRANDT Additional Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1025 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED PI~,EC~PE FOR APPEaRaNCE TO: Prothonotary Please enter the appearance of Richard H. wix, Esquire, of the firm of Wix, Wenger & Weidner, on behalf of Additional Defendant Jason Alan Brandt in the above-captioned matter. WIX, WENGER & WEIDNER Richard H. Wix, Esq., I.D. #07274 Attorneys for Additional Defendant 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 Dated: April 23, 2001 FLANAGAN and BENNER BY: D. HOLBROOK DUER, Esquire I.D. No. 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-94~{ Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS Plaintiffs AARON DAVIDSON Defendant JASON ALAN BRANDT, Additional Defendant No.: 01-1025 JURY TRIAL DEMANDED DEFENDANT DAVIDSON'S OBJECTIONS TO ADDITIONAL DEFENDANT BRANDT'S INTERROGATORIES AND DOCUMENT REOUESTS INTERROGATORIES A. Beyond the scope of permissible discovery under Pa.R.C.P.4003.3: 20 B. Beyond the scope of permissible discovery pursuant to Pa.R.C.P.4003.5: 10 (a), (d), (e): 20 (as to non-testifying experts) C. Beyond the scope of permissible discovery under Pa.R.C.P.4003.1 and 4011: 23 REQUEST FOR PRODUCTION OF DOCUMENTS A. Beyond the scope of permissible discovery under Pa.R.C.P.4003.3: Date: None B. Beyond the scope of pennissible discovei3, pursuant to Pa.R.C.P.4003.5: 7 and 8 (as to non-testifying experts) D. Beyond the scope of permissible d'zscovery under Pa.R.C.P.4003.1 and 4011: None.  ENNER BY: 'D. Hol~fook Duer, ~ I.D. No. 57324 Attorney for Defendant Aaron Davidson CERTIFICATE OF SEKVICE I, D. Holbrook Duer, Esquire, hereby certify that I have this day served a true and correct copy of the foregoing document on the following person and in the manner indicated below: First class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 Richard H. Wix, Esquire Wix, Wenger & Weidner 4705 Duke Street Harrisburg, PA 17109-3099 Date: By: I.D. No. 57324 150 East Chesmut Street Lancaster, PA 17602 Attorney for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS Vs. : DAVIDSON : NO. 011025 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 D HOLBROOK DUER, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3.No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 4/25/01 D HOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 717-397-9444 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILA/)ELPHIA PA 19135 (215) 335-3581 INC. By: Christine J&niszewski File #: M273303 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS VS. DAVIDSON No. 011025 TO: SCOTT MORGAN, ESQ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDD~NT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 4/3/01 Enc (s): File #: Copy of subpoena (s) Counsel return card ~273303 D HOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 INC. By: Christine Janiszewski CO--TH OF p~VANIA COGNTY OF OJ~4RFRI2L~D WILLIAMS & WILLIAMS Vs. DAVIDSON Fi le Nc:). 011025 ORIOINAL X-P~AYS REQUESTED FOR D I SO)VERY PURSUANT TO RULE 4009.22 TO: DR FRANK DELEO, 3400 DERRY ST, HARRISBURG PA 17111 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ocdered by the court to produce the followir~ docunent.~ o~ things: SEE ATTACHED. ADDENDUM --- at MEDICAL LEOAL REPRODUCTIONS<A~.~ss%940 DISSTON ST., imHILA. , PA You may deliver or mail legible copies of the doc~ts o~ p~oduce things requested this subooena, together with the certificate of c~,~]iance, to the party making thi~ request at the address listed above. You have the right to seek in advance the rea~c~abl~ cost of preoaring the copies or producing the things sought. If you fail to produce the docu~nts or things required by this subpoena within t-ent> (20) days after its service, the party serving 'thin subpoena may seek a cou~t ~'de. o:,,~ellincj you to c~,~ly with it. THIS SUBPOENA WAS ISSLIED AT THE RE(~LIEST Of: THE FOLLOWING PERSON: NAME: D HOLBROOK DUER, ESQ ADORESS: 150 E CHESTNUT ST TELEPHONE: SUPREPE COL JRT ID It A~-rORNEY FOR: LANCASTER, PA 17602 215-335-3212 DEFENDANT M273303-01 DATE: '-~/~./,~c./~. ~ ;~; / Seal of the Co~'t BY TD~ COU~T: Prothonotary/~le~k, Civil Oiv~ist~ (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON No. 011025 CUSTODIAN OF RECORDS FOR: DR FRANKDELEO ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENFSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273303-01 Authorized signature for DR FRANK DELEO *** SIGN AND RETURN THIS PAGE *** (IItI3NWEALTH OF pI~R4SYLVANIA WILLIAMS & WILLIAMS VS. DAVIDSON File No. 011025 SUBPOENA TO PROOLJCE DOCLI~NTS OR THINGS FOR DISCX)VERY PURSUANT TO EULE 4009.22 TO: produce the fol lowing doct~ta SUSQUEHANNA VAL PAIN MGMT, 175 LANCASTER BLVD, MECHANICSBURG PA 17055 (Name of Persorl or Entity) Within twenty (20) days after service of this subpoena, you ere ordered by the court to OrS g 'I"I'ACHI D ADDI NDUNI at MEDICAL LEGAL EE~RODOCTIONScA~s~940 DISSTON ST., PHILA., PA You may deliver or mail legible co~ies of the doct~nents or i~oduce things requested this subpoena, together with the certificate of 'c~,uliance, to the partymaking thi~ request at the add. ess listed above. You have the right to seek in advance the reasonable cost of preoa~ing the copies or producing the things sought. If you fail to produce the dOCtlllents or things recluired by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court orde,- o~,~ellin9 you to c~]y with it, TH I $ SUBPOENA WAS ISSUED AT THE REGUEST O~ THE FOtLOWI NG PERSON: NAP~: D HOLBROOK DUER, ESQ ADORESS: 150 E CHESTI~JT ST TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: hANCAS'f=R, PA 17602 215-335-3212 M273303-02 DEFENDANT DATE: seal of ~he c°urt BY TFE OOURT: prothonotary/Cl~rk, Civil Division (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON NO. 011025 CUSTODIAN OF RECORDS FOR: SUSQUEHANNA VAL PAIN MGMT ANY AND ALL RECORDS, INCLUDING ANY MEDICAL RECORDS FROM THE PAIN CLINIC AT HEALTHSOUTH OF MECHANICSBURG AND MALIK MOMIN, M.D. AT ANY TIME. PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN £ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273303-02 Authorized signature for SUSQUEHANNA VAL PAIN MGMT *** SIGN AND RETURN THIS PAGE *** cO--TH OF P]~rLVANIA WILLIAMS & WILLIAMS Vs. DAVIDSON Fi]eNo. 011025 SUBPOENA TO PR(ZXJCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CENTRAL PENNA SPINAL ASSO, 805 SIR THOMAS CT, (Name o{ Person o~ Entity) HARRISBURG PA 17109 Within twenty (20) days altar service of this subpoena, you are o~de~ed by the court to at MEDICAL LEeAL REPRODUCTIONS[A~s~940 DISSTON ST., PHILA., You may delive~ o~ mail legible co~ies of the doctments c~ i:~oduce things requested this subpoena, togethe~ with the certificate of' co%~liance, to the pa~ty making thiz request at the address ]isted above. You have the right to seek in advance the rea~onabl( cost of preparing the copies o~ producing the things sought. If you fail to produce the doc~m~nts o~ things required by this subpoena within twenty (20) days afte~ its service, the party serving 'thin r~ubpoena may seek a court ocde~-, ~m~elling you to c~-,~ly with it. ~ THIS SUBPOENA WAS ISSUED ATTHERE(~ESTOFTHEFOLLOWlNGPERSON: NAME: D HOLBROOK DUER, ESQ ADORESS:__ 150 E CHESTNUT ST TELEPHONE: SUPREME COURT ID # A1-FORNEY FOR: hANcA~T~k, PA 17602 215-335-3212 DEFENDANT M273303-03 Se~I of the'Oou~t BY THE COURT: ' ProthonOta~y/O4e~k, CiViT Divisio~ (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON No. 011025 CUSTODIAN OF RECORDS FOR: CENTRAL PENNA SPINAL ASSO ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ADDRESS: DATE 0F BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( } RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273303-03 Authorized signature for CENTRAL PENNA SPINAL ASSO *** SIGN AND RETURN THIS PAGE *** WILLIAMS & WILLIAMS Vs. DAVIDSON ~TH OF p~SYLVANIA ~ OF Ct~R~IAt~ 011025 SUBPOENA TO PROOUCE DOOJI~NTS OR TH I NQS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: REHAB MED ASSOCS, C/O DR JAY CHO, 5124 E TRINDLE RD MECHANICSBURG PA 17055 (N~neof Persc~qor Entity) pr. oduce the fo1 lowing docLment.~ OrS g % jS [CHED ADDENDI39~ Within twenty (20) days after service of this subooena, you ere ordered by the court to PHILA. , PA ......... You may deliver or mail lecjible copies of the doc~ts or produce things requested this suboc~a, together with the certificate 6f' CC~liar~e, to the party making this request at the address listed above. YOU have the right to seek in advance the rea~on~le cost of oreoaring the cc~ies or producing the thirsts s~t. If you fail to produce the docunents or thir~ re~ired by this subpoena within twenty (20) days after its serv(ce, the par.ty serv*ng O~i.~ subf:x~na may seek a court orde,- c~Delling you to c~ly with it., THIS SUBPOENA WAS ISSUED AT THE REC~JEST OF TI~ FQLLCI~INQ PERSON: NAME: D DIOLBROOK DUER, ESQ TELFPHONE: SUPRE]VE COURT ID ATTORNEY FOR: DEFENDANT M273303-04 DATE: See] Of theC~3urt Im~'ot. hano~y/Cl~k~'(~ivi 1 Divisio~ Deputy (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON No. 011025 CUSTODIAN OF RECORDS FOR: REHABMED ASSOCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: DATE NAME: ADDRESS: OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 CERTIF/ED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN ( ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ( ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273303-04 Authorized signature for REHAB MED ASSOCS *** SIGN AND RETURN THIS PAGE * ** WILLIAMS & WILLIAMS VS. DAVIDSON CO--TH OF p~SYLVANIA G~TY OF ~ File No. 011025 ORIGINAL X-RAYS REQUESTED SUBPOENA TO PROfXJCE DOOJ~NTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR KATHERINE GALLAGHER, 4076 MARKET ST, CAMP HILL PA 17011 (N~me of Person o~ Entity) Within twenty (20) days after service of this subpoena, you a~e o~de~ed by the court to produce the fol lowing docu~t.~ o~ thinqs,: , SEE A I"rACH -- ' at MEDICAL LEGAL REPRODUCTIONS,(A~sS%940 DISSTON ST., PEILA., PA You may deliver or mail legible copies of the dooznents or produce things requested this subpoena, to~ether with the certificate of co,~liance, to the party making thi~ request at the address listed above. You have the right to seek in advance the reasonable cost of preoaring the copies or producing the things sought. If you fail to produce the doc~nents or things required by this subpoena within t-enty days after its service, the party serving thi.~ subpoena may seek a court ~'de.' o~pellin~ you to oa,~ly with it. 'IH I S SUBPOENA WAS ISSUED AT THE REQJEST OF THE FOLLOWING PERSON: NAMe: D HOLBROOK DUER, ESQ 150 E CHEST~2T ST TELEPHONE: ~IPREI~E O3URT ID # ATTORNEY FOR: LANCASTer, PA 17602 215-335-3212 DEFENDANT M273303-05 DATE: "Y~ .~ ~2.z~c? S~al of th~ Oou~t BY ~ (X)URT: ~roth~tary~l~k, Civil Oivis~ (Elf. ~/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON No. 011025 CUSTODIAN OF RECORDS FOR: DR KATHERINEGALLAGHER ANY AND ALL MEDICAL RECORDS FOR ANY TIME INCLUDING BUT NOT LIMITED TO 2/24/99 LUMB/~R SPINE, DORSAL SPINE, CERVICAL SPINE A/qD LEFT SHOULDER X-RAYS, AS WELL AS ANY OTHER X-RAY FILMS AT ANY TIME. PERTAINING TO: NAME: D/)DRESS: DATE OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COI',IPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENFSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLD/~D M273303~05 Authorized signature for DR KATHERINE GALLAGHER *** SIGN AND RETURN THIS PAGE *** c~TH OF pf~-YLVANIA COONTY OF Ct~FRLA~D WILLIAMS & WILLIAMS VS. DAVIDSON Fi le No. 011025 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SU~P0~NA TO PROOUCE DOCI~E~S OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: MAGNETIC IMAGING CTR, 4665 TRINDLE RD, MECHAIgICSBURG PA 17055 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, yo~ are ordered by the court to at MEDICAL LEGAL REPRODUCTIONS~d~gs)4940 DISSTON ST., PHILA., PA You may deliver or mail legible cc~ies of the doctznents or produce things requested this subooena, together with the certificate of cc~liance, to the party, making thi~ request at the address listed above. You have the right to seek inadvance the reasonable Cost of preoarin9 the copies or producing the things sought. If you fail to produce the doctments or things required by this subpoena within twent~ (20) days after its service, the party serving thin subpoena may seek a court orde.' oc~pellir~J you to c,~ly with it. TH I S SUBPOENA WAS ISSUED AT THE RE(~EST OF THE FOLLOW I NG PERSON: NAMe: D HOLBROOK DUER, ESQ ADORESS: 150 E CHESTNUT ST hANC~'rw.~, PA 17602 TELEPHONE: SUPREPE CXiKJRT ID # 215-335-3212 ATTORNEY FOR: DEFENDANT M273303-06 DATE: /n~ · BY THE CO JRT: /! (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON NO. 011025 CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CTR ANY AND ALL X-POkY AND MRI FILMS FOR SANDRA WILLIAMS AT ANY TIME, INCLUDING BUT NOT LIMITED TO 11/2/99 LUMBAR SPINE MRI AND 10/8/99 CERVICAL SPINE MRI. TO INCLUDE MEDICAL RECORDS A31D BILLS. PERTAINING TO: DATE NAME: ADDRESS: OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273303-06 Authorized signature for MAGNETIC IMAGING CTR * ** SIGN AND RETURN THIS PAGE *** ' C~TH OF pfd.]SYLVANIA G~JN~Y OF O~mFREA~) WILLIAMS & WILLIAMS, Vs. DAVIDSON ~ileNo. 011025 ORIGINAL X-rAYS REQUESTED FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: QUANTUM IMAGING & THERAP, 3508 TRINDLE RD, CAMP HILL PA 17011 (Nm of Person or Entity) Within twenty (20) days after service of this subpoena, you ere ordered by the coumt to produce the followin~ docunent.~ or things: SEE ATTACHED ADDI NOUM - at MEDICAL LEGAL REPRODUCTIONS,(A~.~ss~940 DISSTON ST., PEILA., PA You may deliver or mail legible copies of the doct~nents or produce things requested this subpoena, together wtth the cemtificate of"o~-,~]iance, to the party makin9 this request at the address listed above. You have the might to seek in advance the reasonable cost of preoarin9 the copies or producin9 the things sought. If you fail to pr~xluce the doccrnents or things required by this subpoena within twenty (20~ days after its service, the party serving 'thin ;~ubpoena may seek a court orde,- c~,~eli~n9 you to ccnply w~th it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PER~3N: TELEPHONE; SUPREME COURT ID ATTORNEY FOR:' D HOLBROOK DUER, ESQ 150 E CHESTNUT ST LANCAST~i~, FA 17602 215-335-3212 DEFENDANT M273303-07 Seal of thei0ourt~ BY THE CX:XJRT: Prothon0ta~y/ClerR, ~ 1 Division Deputy (Elf. '/'/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON No. 011025 CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING &THERAP ANY AND ALL X-RAY AND MRI FILMS FOR SANDRA WILLIAMS, AT ANY TIME, INCLUDING BUT NOT LIMITED TO A 10/6/99 CERVICAL SPINE X-RAY. TO INCLUDE MEDICAL RECORDS AND BILLS. PERTAINING TO: NAME: SANDRA D WILLIAMS ADDRESS: 9 S HUMER ST ENOLA PA DATE OF BIRTH: 09/09/52 SSAN: 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. £ ] NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273303-07 Authorized signature for QUANTUM IMAGING & THERAP *** SIGN AND RETURN THIS PAGE *** WILLIAMS & WILLIAMS : Vs. : DAVIDSON : File No. 011025 MEDICAL BILLING REQUESTED SUBPOENA TO PR(X~JCE OOCUMENTS OR THIN~S FOR D I SCOVERY PURSUANT TO RUtE 4009.22 TO: NATIONWIDE, PO BOX 2655, HARRISBURG PA 17104 ATTN: WAMDA WEISER (N~ne of Person o~ Entity) Within twenty (20) days afte~ service of this sub~oena, yo~ a~e o~de~ed by the court to ADDENDUM at MEDICAL LEGAL REPRODUCTIONS~A~s)4940 DISSTON ST., PHILA., PA Yo~ may delive~ o~ mail legible cooies of the doc~ts o~' p~oduce things requested this subpoena, togethe~ with the certificate of c~r~liance, to the party making thi~ request at the edd~ess listed above. You have the right to seek in advance the reasonable cost of preoaring the copies or producing the things sought. If you fail to produce the doo~nents o~ things required by this subpoena within twenty (20) days afte~ its service, the party serving thin ~ubpoenamay seek a court orde.' c,'r~Deliing you to Cu,ply withit. TH I S SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: D HOLBROOK DUER, ESQ ADORESS: 150 ~ ~H~,.qTNTTT ST TELEPHONE: ~UPREFE COURT ID # ATTORNEY FOR: LANCAST~ZR, PA 17602 215-335-3212 DEFENDANT M273303-08 DATE: "'~ ~' ~, ..,'~., Se~l of thd'Oou~t (Eff. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON No. 011025 CUSTODIAN OF RECORDS FOR: NAT[O~E **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRAD WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] [ ] RECORDS ARE ATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS AVA1LABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M273303-08 Authorized signature for NATIONWIDE *** SIGN AND RETURN THIS PAGE *** MEDICAL LEGAL REPRODUCTIONS, ]_NC. 4940 Disston Street · Philadelphia, PA 19135 (215) 335-3212 · Fax (215) 338-2980 The Jefferson Building · 1015 Chestnut Street * Suite 926 · Philadelphia, PA 19107 Post Office Box 504 · Palmyra, NJ 08065 · (609) 541-5548 ADDEITDUM NATIONWIDE INS CO DECLARATION PAGE FOR THE 2/23/99 MOTOR VEHICLE ACCIDENT; (CLAIM #2416356044USS); PROPERTY DAMAGE INVESTIGATION AND PHOTOGRAPHS; ACCIDENT INVESTIGATION AND PHOTOGRAPHS; ANY AND ALL STATEMENTS, PAY-OUT SHEETS FOR BOTH WAGE LOSS AND MEDICAL BENEFITS; ALL MEDICAL RECORDS, REPORTS AND BILLS; PRO REPORTS; APPLICATIONS FOR BENEFITS; CORRESPONDENCE TO AND FROM ALL MEDICAL CARE PROVIDERS AND INSURED(S); ANY AND ALL ADJUSTER LOG NOTES FOR THE 2/23/99 MOTOR VEHICLE ACCIDENT AND ANY AND ALL OTHER ACCIDENTS INVOLVING SANDRA D WILLIAPIS WHILE INSURED BY NATION-WIDE INSURkNCE COMPANY. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL NO. 01 1025 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 D HOLBROOK DUER, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3.No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 06/26/01 File #: M275847 D HOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 717-397-9444 ATTOPuNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) INC. By: Christine Janiszewski IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS VS. DAVIDSON, ET AL No. 01 1025 TO: SCOTT MORGAN RICHARD WIX NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDD/TT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 06/05/01 D HOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 INC. By: Christine Janiszewski Eric(s): File Copy of subpoena(s) Counsel return card M275847 WILLIAMS & WILLIAMS VS. ' .DAVIDSON, ET AL File ~o. 01 1025 ORIGINAL X-PAYS REQUESTED M~DICAL BILLING REQUESTED SUBPOENA TO PROOUCE DOCt~ENTS ~R THINGS FOR DISCOVERY PURSUANT TO RU~E 4009.22 TO: HARRISBURG HOSP, 111 S FRONT ST, HARRISBURG PA 17101 ATTN: MEDICAL RECORDS DEPT (Neme of Perso~ o~ Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to AuUI NDLT-M MEDICAL LEOAL REPRODUCTIONS(A~Kq§a4940u,,.r= ~ DISSTON ST., PHILA., PA You may deliver or mail legible copies of the,~ts or produce things requested this subpoena, together with the certificate 6f ~'c~Dliance; - to the party making thi[ request at the address listed above. You have the right to seek in advance the rea~,onable cost of preparing the copies or Drc~ducing the things sc~ght. If you fail to produce the doc~aents or t~ings required by this subpoena within twenty (20) days after its serv';ce, .. ~he p.ar,ty~, ser.v?gg.~ ithlo ,~,.~u~o~n. a may seek a court orde~- oc~pelling you to ~.,.,.ly wi,th ~t~!. : ' ~ ' ' TH I S SUI~OOENA WAS ISSUED AT THE RE(~EST (~ T~[ FOI. L~I NG PERSON: NAMe: D HOLBROOK DUER, ESQ ADORE~: 150 E CHESTNUT ST ' ' ~ ...... ~ ~ "'" 19602 hA~cA~'r ~.R, PA TELEPHONE: ' SUPREme[ (X1JRT ID # 215-335-3212 ATTORNEY FOR: DEFENDANT M275847-01 (Elf. ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 01 1025 CUSTODIAN OF RECORDS POR: HARRISBURG HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: SANDRA D WILLIAMS ADDRESS: 9 S HUMER ST ENOLA PA DATE OF BIRTH: 09/09/52 SSAN: 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED TO INCLUDE EMERGENCY ROOM RECORDS. ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND R. ETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTSAVAILABL~:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS XRAYS have been destroyed Date CUMBERLAND M275847-01 Authorized smgnature for HARRISBURG HOSP *** SIGN AND RETURN THIS PAGE *** C~TH OF pI~INSYLVANIA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL File No. 0i 1025 ORIQINAL X-I~AYS REQUESTED M~DICAL BILLIN~ REQUESTED SUBPOenA TO PROOtK~ O(X~UM~NTS O~ FO~ O l SOOV~RY PURSUANT TO RUtE 4009.22 TO: SEIDEL HOSP, 120 S FILBERT ST, MECH~ICSBURG PA 17055-6591 ATTN: MEDICAL RECORDS DEPT (Name of Pe~son o~ Entity) Within twenty (20) days afte~ service of this sub~oena, you a~e o~de~ed by the court to at "~. MEDICAL LEGAL REPRODUCTIONS"~I~C6sA940tauuv s; DISSTON ST. PHILA., PA You may deliver oc mail legible copies Of the docunents o~ p~oducs things requested b) this subpoena, together with the certificate Of 'cca~liance;- to-the party making this request at the add. ess listed above. You have the right to seek in advance the rea~onabl~ cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t~enty (20) days after its sarv':ce, the pa~ty seFvtng thin ..$~.~u~ena may seek a co~t o~de,- ~,wellJng you to cuJ~ly withe:it..? ~[', ' :' ' ' ' ' THIS SUBPOENA WAS ISSUED AT THE RE(~/JEST O~ THE FOLLOWING PERSON: TELEPHONE: .~ : ~UPREME COURT ATTORNEY FOR: D HOLBROOK DUER, ESQ 150 E CHESTNUT ST I~NCAS'£~K, PA 17602 215-335-3212 DEFENDi~NT .%{275847-02 ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS VS. DAVIDSON, ET AL No. 01 1025 CUSTODIAN OF RECORDS FOR: SE~)ELHOSP ANY AND ALL RECORDS, X-RAYS AND BILLS, INCLUDING D~LL PHYSICAL THERAPY AND MEDICAL RECORDS, AT ANY TIME, INCLUDING BUT NOT LIMITED TO PHYSICA25 THERAPY IN 1997. PERTAINING TO: NAME: SANDRA D WILLIAMS ADDRESS: 9 S HUMER ST ENOLA PA DATE OF BIRTH: 09/09/52 SSAN: 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDS AREATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTSAVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M275847-02 Authorized signature for SEIDEL HOSP *** SIGN AND RETURN THIS PAGE *** ~TH OF FHIqNS~LVANJA WILLIAMS & WILLIAMS : : Vs. : DAVIDSON, ET AL : File No. 01 1025 ORIGINAL X-PAYS REQ~STED MEDICAL BILLING REQ~STED SUBPOENA TO PROOUCE IXX::IJI4~NTS OR THINGS FOR D I SOOVERY PURSUANT TO RULE 4009.22 TO: CAPITAL AREA CARDIO SUR~, 423 N 21ST ST, CAMP HILL PA 17011 (Name of Person o~ Entity) Within twenty (20) days afte~ service of this subpoena, you m'e ocde~ed by the court to oroduce the Fol]c~{~ docu~e~t.~ O S TTACiiED ADDENDUM at MEDICAL LEGAL REPRODUCTIONSj ~1~-~. 40 DISSTON ST., (Address) PHILA., You may delive~ o~ mail legible copies of the doctn~nts o~ produce things requested b~ this subpoena, togethe~ with the certificate of co,oliance, to the party making this request at the add~ess listed above. YOU have the right to seek in advance the rea~.onable cost of preparing the copies or producing the things sought. If you fail to produce the docunents o~ things required by this subpoena within twenty days afte~ its service, the party serving thi-~ subpoena may seek a court orde~' =~,welling you to o~,~ly with it. THIS SUBI:~DENAWAS ISSUED ATTHEREQUESTOFTHEFOLLOWINGPERSON: NAME: D HOLBROOK DUER, ESQ ADORE$S:. 150 E CHESTNUT ST LANCAmTER,' PA 17602 215-335-3212 TELEPHONE: SUPREP[ COtJRT ATTORNEY FO~: M275847-03 DATE: DEFENDANT (Elf, 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 01 1025 CUSTODID/~ OF RECORDS FOR: CAPFFALAREA CARDIO SURG ANY ~ ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CD~RDS AND ~ OTHER INFORMATION RELATING TO /LNY EXAMINATION OR TREATMENT RENDERED TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRAD WILLIA~4S 9 S HUMER ST ENOLA Pa 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS XRAYS have been destroyed Date CUMBERLAND M275847-03 Authorized sxgnature for CAPITAL ~-REAC/LRDIO SURG *** SIGN AND RETURN THIS PAGE *** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL NO. 011025 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 D HOLBROOK DUER, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3.No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 08/28/01 D HOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 717-397-9444 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) INC. By: Christine Janiszewski File #: M277888 IN TI4F, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS DAVIDSON, ET AL No. 011025 TO: SCOTT MORGAN RICHARD WIX NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 08/07/01 D MOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 ATTORNEY FOR DEFENDANT INQUIRIES SKOULD BE ADDRESSED TO~ MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 INC. By: Christine Jmniszewski Enc(s): File #: Copy of subpoena(s) Counsel return card M277898 WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL (Xk~TH OF P]~-"/L%rAN-/A (IK3NTY OF C~I2t Fi le No. 011025 SUBPOENA TO PROOUCE ~NTS OR TH I NQS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: TRINDLE REI~ MED CTR, 5124 E TRINDLE RD, MECHANICSBURG PA 17055 (N~ne of Person or Entity) Within twenty (20) days after service of this subpoena, you ere o~dered by the court to n · produce the fol lowir~ docu~ent.~ o~tJ~ i TACHED ADDEND~ at MEDICAL LEGAL ~EPRODOCTIONS,(A~s~9%0 DISSTON ST., PHILA., PA You may deliver o~ mail legible cc~ies of the doccrnents or produce things requested this subpoena, together with the certificate of c~,~liance, to the party making thiz request at the address listed above. You have the right to seek in advance the rea~onab1( cost of preparin9 the cc%oies or producing the things s~ght. If you fail to produce the doctments or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court orde~- ozmpelling you to c~,~ly with it. TH I S SUB~NA WAS ISSUED AT Th~ RE(~ST OF THE FOLLO~IN(~ PERSON: NAME: D HOLBROOK DUER, ESQ ADORESS: 150 E CHESTNUT ST TELEPH(~E: ~;UPREME CX:~RT ID ATTORNEY FOR: LANCACTER, 'PA 17602 215-335-3212 DEFENDANT M277888-01 ~$/28/01 DATE: Seal bfthe'Court BY 'R-~ COURT.: /") (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: TRINDLEREHABMED CTR ANY /%ND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND AbPf OTHER INFORM3~TION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 TO INCLUDE ALL PHYSICAL THERAPY RECORDS AT ANY TIME. CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M277888-01 Authorized signature for TRINDLE REM/kB MED CTR *** SIGN AND RETURN THIS PAGE *** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS Vs. DAVIDSON NO. 011025 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOEN& PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) pursuant 1. o 3 o for documents and things to Rule 4009.22 D HOLBROOK DUER, ESQUIRE certifies that: A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, No objection to the subpoena(s) has been received, and The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 11/21/01 D HOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 717-397-9444 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) INC. By: Christine Janiszewski File #: M280630 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS VS. DAVIDSON No. 011025 TO: SCOTT MORGAN NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical the one(s) attached to this notice. You have twenty (20) from the date listed below in which to file of the undersigned an objection to the subpoena. made the subpoena may be served. to days record and serve upon If no objection is Date: 10/31/01 D HOLBROOK DUER, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISST~ON STREET PHILADELPHIA, PA 19135 (215) 335-3336 INC. By: Christine J&niszewski Enc (s): File #: Copy of subpoena(s) Counsel return'card M280630 cO--TH OF p]~%lNSYLVANIA O3~NTY OF O3~ WILLIAMS & WILLIAMS : Vs. : DAVIDSON File No. 011025 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA lO PROO~O5 DCO3MENTS O~ THIN~S FO~ DISCOVERY PURSUANT TO RUtE 4009,22 TO: DR MARK GRUBB, 875 POPI~AR CHURCH RD, CAMP HILL PA 17011 (Name of Person or Entity) Within tweoty (20) days afte~ service of this subpoena, you a~e o~de~ed by the court to produce the fol lowin at You may deliver o~ mail legible copies of the documents o~ produce things requested b~ this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days afte~ its service, the party serving thin subpoena may seek a court orde,' ~,~elling you to co',~ly with it. THIS SLI~POENAWAS ISSUED ATT HE REOUESTOFTHEFOLLOWINGPERSON: NAME: D HOLBROOK DUER, ESQ Al%ChqE~: 150 E CHESTNUT ST TELFPHONE: SUPREME COURT ID ~ ATTORNEY FOR: LANCASTER, 'PA 17602 21~-335-3212 DEFENDANT M280630-01 OATE: Seal of the Ocx~rt BY ~ O0URT: Prothonotary$'CYerk, C~vil Oivisio~ D~outy (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON No. 011025 CUSTODIAN OF RECORDS FOR: DR MARK GRUBB ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-P~AY REPORTS, HISTORY NOTES, INDEX CARDS AND /LNY OTHER INFORMATION RELATING TO ~ EXAMINATION OR TREATMENT RENDERED TO: DATE NAME: ADDRESS: OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ NO DOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS XRAYS have been destroyed Date CUMBERLAi~D M280630-01 Authorized signature for DR MARK GRUBB *** SIGN AND RETURN THIS PAGE *** SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w, Plaintiffs AARON DAVIDSON, Defendant JASON ALAN BRANDT Additional Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1025 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD To: Aaron Davidson; and D. Holbrook Duer, Esquire, Attorney for Defendant You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. WIX, WENGER & WEIDNER Dated: Richard H. Wix, Esq., I.D. #07274 Attorneys for Additional Defendant 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w, Plaintiffs v. AARON DAVIDSON, Defendant v. JASON ALAN BRANDT Additional Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1025 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED 2. 3. 4. 5. ~NSWER WITH NEW MATTER OF JASON ALAN BRANDT TO COMPLAINT OF AARON DAVIDSON Admitted. Admitted. Admitted. Denied. Denied. 6. Plaintiffs' provisions of the Responsibility Law. 7. Additional Defendant's vehicle did Plaintiff's vehicle and caused the Plaintiff no NEW MATTER claim is barred in whole or part by the Pennsylvania Motor Vehicle Financial WHEREFORE, Defendant. not strike injuries. the Additional Defendant demands judgment against the Respectfully submitted, WIX, WENGER & WEIDNER Dated: Richard H. Wix, Esq., ID# 07274 Attorneys for Additional Defendant 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 VERiFiCaTiON I, Richard H. Wix, Esquire, attorney for the Additional Defendant in this matter, verify that the statements made in the foregoing Answer with New Matter of Jason Alan Brandt to Complaint of Aaron Davidson are true and correct to the best of my knowledge, information and belief. The undersigned understands that his statements therein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Richard H. Wix, Esquire Dated: 3/~/0 ~ CERTIFiCaTE OF SERVICE AND NOW, this 4th day of March, 2002, I, Richard H. Wix, Esquire, of the firm of Wix, Wenger & Weidner, attorneys for Additional Defendant, hereby certify that I served the within Additional Defendant's Answer with New Matter to Defendant's Joinder ComDlaint this date by depositing a copy of same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed as follows: D. Holbrook Duer, Esq. Flanagan & Benner 150 East Chestnut Street Lancaster, PA 17602 Scott Morgan, Esq. Morgan & Morgan 120 South Street Harrisburg, PA 17101-1210 WIX, WENGER & WEIDNER Richard H. Wix, Esq., I.D. ~07274 Attorneys for Additional Defendant 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 FLANAGAN and ASSOCIATES BY: Brian A. McCall, Esquire I.D. No. 83030 150 East Chestnut Street Lancaster, PA 17602 Attorneys for Defendant (717) 397-9~.~.a. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS Plaintiffs AARON DAVIDSON Defendant JASON ALAN BRANDT, Additional Defendant No.: 01-1025 JURY TRIAL DEMANDED PRAECIPE FOR ENTRY / WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of D. Holbrook Duer, Esquire and enter the appearance of Brian A. McCall, Esquire on behalf of Defendant, Aaron Davidson. All papers may be served on Flanagan and Associates, 150 East Chesmut Street, Lancaster, PA 17602. FLANAGAN AND DUER By: ~uire I.D. No.: 57324 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Dated: ~7 0///~-~ FLANAGAN AND ASSOCIATES -~'l~t~o. 83030 150 ~st Ches~ut S~eet ~cas~r, PA 17602 (717) 397-9~4 Da~d: ¢~¢~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this day I served a true and correct copy of the foregoing documem, upon the following and in the manner indicated below. Service was made by First Class Mail, addressed as follows: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, Pa 17101-1210 Richard H. Wix, Esquire Wix, Wenger & Weidner 4705 Duke Street Harrisburg, PA 17109-3099 FLANAGAN AND DUEP~._., i :McC ire ~ No.: 83030 150 East Chestnut Street Lancaster, PA 17602 (717) 397-?. ~/. Attorneys for Defendant Dated: FLANAGAN and ASSOCIATES BY: BRIAN A. McCALL, Esquire I.D. No. 83030 1~0 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorneys for Defendant Aaron Davidson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SANDRA D. WILLIAMS and THOMAS WILLIAMS Plaintiffs AARON DAVIDSON Defendant JASON ALAN BRANDT, Additional Defendant Civil Action No.: 01-1025 Answer and New Mater to Plaintiff's Complaint and Joinder Complaint as if fully set forth DEFENDANT'S ANSWER TO NEW MATTER OF JASON ALAN BRANDT TO COMPLAINT OF AARON DAV1DSON 1. - 5. Answering Defendant, Aaron Davidson, incorporates herein by reference its herein. 6. The averments contained in paragraph 6 are conclusions of law to which no responsive pleading is required. To the extent a response is necessary, the averments in paragraph 6 are denied. Strict proof of same is demanded at the time of trial. 7. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph 7. Accordingly, same is denied. Strict proof is demanded at the time of trial. JURY TRIAL DEMANDED WItEREFORE, Answering Defendant requests that judgment be entered in his favor against all other parties to this action. Date: f 2~g(fo~2~ FLANAGAN and ASSOCIATES I,~rT. No. 83030 ~ 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorney for Defendant Aaron Davidson VERIFICATION I, BRIAN A. McCALL, ESQUIRE, hereby verify that I am the attorney for Defendant AARON DAVIDSON in the foregoing action and that the averments if the attached DEFENDANT'S ANSWER TO NEW MATTER OF JASON ALAN BRANDT TO COMPLAINT OF AARON DAVIDSON are true and correct m the best of my knowledge, information and belief. I understand that I am subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities for any false statements made herein. CERTIFICATE OF SERVICE I, Brian A. McCall, Esquire, hereby certify that I have this day served a tree and correct copy of the foregoing document on the following person and in the manner indicated below: First class mail, postage pre-paid: Scott Morgan, Esquire Morgan & Morgan, P.C. 120 South Street Harrisburg, PA 17101-1210 Richard H. Wix, Esquire Wix, Wenger & Weidner 4705 Duke Street Harrisburg, PA 17109-3099 Date: FLANAG~,AN and A~~ 150 East Chestnut Street Lancaster, PA 17602 (717) 397-9444 Attorney for Defendant Aaron Davidson pRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and sulxnitted in duplicate) TO THE P~OTHONOTARY OF CUMBERLASD COUNTY Please list tho following case: (Check one) ( X ) for JURY trial at the next term of civil court. ( ) for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) SANDRA D. WILLIAMS and THOMAS WILLIAMS VS. AARON DAVIDSON ( Plaintiff ) ( Defendant ) vs. JASON ALAN BRANDT (check one ) (x) ( ) ( ) Civil Action - Law Appeal from Arbitration (other) The trial list will be called on 10/7/03 and Trials commence on 11 / 3 / 03 Pretrials will be held on 10 / 15 / 03 (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 01-1025 19 Indicate the attorney who will try case for the party who files this praecipe: Richard H. Wix, ESQ.. Attorney for Jason Alan Brandt. Additional Defendant Indicate trial counsel for other parties if known: Scott Morgan, Esq., Attorney for Plaintiff. 120 South. St., Harrisburq, PA Brian A. McCall, Esq. ~ Attorney for Defendant, 150 E. Chestnut St., Lancaster, PA This case is ready for trial. Date: 9/15/03 Print Name: Richard H. Wix, Esq. Attorney for: Additional Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL NO. CERTIFICATE 011025 PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 BRIAN A MCCALL, ESQUIRE certifies that: 1o A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to Intent the subpoena(s) which is attached to the Notice of to Serve the Subpoena(s). Date: 09/10/03 BRIAN A MCCALL, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 717-397-9444 ATTORi~EY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) INC. By: Sandra Otto File %: M302490 lin THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILLIAMS & WILLIAMS VS. DAVIDSON, ET AL No. 011025 TO: SCOTT MORGAN, ESQ (PIJIINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 08/19/03 BRIAN A MCCALL, ESQUIRE 150 E CHESTNUT ST LANCASTER, PA 17602 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335--3336 INC. By: Sandra Otto Enc(s) : Copy of Counsel File ~: M302490 subpoena(s) return card WILLIAMS Vs. DAVIDSON, & WILLIAMS ET AL (I~TH OF p~YLVANIA : Fi le No. 011025 SUBPOENA TO PROOUCE DOCUMENTS OR TH I NOS FOR O l SCOVERY PURSUANT TO RULE 4009.22 TO: HARRISBURG HOSP, 111 S FRONT ST, HARRISBURG PA 17111 ATTN: MRDTCAT. RECORDS DEPT (Name of Person o~ Entity) Within twenty (20) days afte~ service of this subpoena, you a~e o~dered by the court to produce the fol lowing docunent.~ or things: SEE ATTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS(A~ss~940 DISSTON ST., PEILA., PA You ~y deliver or n~il legible copies of the doctmaents or p~oduce things requested bt this subpoena, to~Jether with the certificate of cu,~liance, to the party making this request at the address listed above. You have the right to seek in advance the rea~nabl~ cost of preoaring the copies or producing the things sought. If you fail to pmoduCe the docunents or things required by this subpoena within twenty (20) days after' its sarvlce, the party serving 'thin subpoena may seek a court orde~ ccnDelling you to c~,'~ly with it. THIS SUSPOENAWAS ISSUED ATTHE RE(IUESTOFTHE FOLLOWlNG PERSON: RRTAN A MCC~T.L, ESQ ADDRESS: 150 E CHESTNUT ST TELEPHONE: SUPREPE COURT ID # ATTORNEY FOR:_ LANCASTER, PA 17602 215-335-3212 DEFENDANT M302490-01 Seal Jof the Coumt ...... Pr othonotar y_~K'~ll~k, Ci¥i~Divisien (Eff. 7/97) ADDENDUM TO ~UBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: HARRISBURG HOSP ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THEP3~PY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMORANDA, CORRESPONDENCE AND ANY AND ALL MEDICAL REPORTS AIqD BILLING INFORMATION FROM 6/1/01 TO PRESENT. PERTAINING TO: DATE NAME: ADDRESS: 0F BIRTH: SSAN: SA/qDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/~2 179448562 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERI3kND M302490-01 ~uthorized signature for HARRISBURG HOSP *** SIGN AND RETURN THIS PAGE *** co--TH OF pf2~L~LVANIA c0tm~fY OF C3MBERUU~D WILLIAMS & WILLIAMS VS. DAVIDSON, ET AL File No. 011025 ORIGINAL X-PAYS REQUESTED SUBPOENA TO PRO[TJCE ~NTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HARRISBURG HOSP-X, 111 S FRONT ST, H/LRRISBURG PA 17111 ATTN' RADIOLOGY DEPT (Name of Person o~ Entity) Within twenty (20) days afte~ service of this sub~ema, you a~eo~de~ed by the court to produce the following doc%xne~t~ o~ things. SEE ATTACHED ADDENDUM MEDICAL LEGAL REPRODUCTIONS%A~a~ss~940 DISSTON ST., PHI~.A., You may delive~ o~ mail legible ccoies of the documents o~ 0~oduce things requested this sub~ena, togethe~ with the certificate of ou,~liance, to the pa~ty making thiz request at the add~ess listed above. YOU have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the doct~nts or things required by this subpoena within twenty (20) days after its semv~ce, the party serving thi~ subpoena may seek a court order' ~.~,~elling you to Cu,~ly with it. TH I S SUBI~gENA WAS ISSUED AT THE REQUEST OF THE FOLLGN I NG PERSON: NAME: RRTAN A MCCALL, ESQ ADORESS: 150 E ClIESTNUT ST TELEPHONE: SUPRE~ COURT ID # ATTORNEY FOR: LANCASTER, PA 17602 215-335-3212 sY THE COURT: Deputy (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: HARRISBI3q{GHOSP-X SPECIFICALLY **LIMITED** TO DIAGNOSTIC FILMS FROM 6/1/01 TO PRESENT. PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENFSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): RECORDS ( ) PATIENT BILLING X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M302490-02 Authorized signature for HARRISBURG HOSP-X *** SIGN AND RETURN THIS PAGE *** WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL File No. 011025 SUBPOENA TO PROOUCE ~NTS OR TH II~S FOR D I SCOVERY PURSUANT TO RULE 4009.22 TO: SEIDLE HOSP, 120 S FILBERT ST, MECHANICSBURG PA 17055-6591 ATTN: MRDICAL RECORDS DEPT (Name of Person o~ Entity) Within twenty (20) days after service of this subpoena, you are ocdered by the court to produce the followir~ docunent.~ o~ things: SEE A'I"I'ACH :D ADDENDUM at MEDICAL LEGAL REPRODUCTIONS(A~2s~940 DISSTON ST., PHILA. , PA You may deliver o~ mail legible copies of the doc~m~ats or produce things requested this subpoena, together with the certificate of c~,uliance, to the party making thi[ request at the add~ess listed above. You have the right to seek in advance the rea~onabi~ cost of Preoaring the Cx3Dies or oroducing the things sought. If you fail to produce the docunents or thir~3s required by this subpoena within twenty days after its service, the party s~J'ving thi~ subpoena may seek a court orde;- o~,~el]ir~3 you to c~,~ly with it. TH I S SUBPOENA WAS ISSUED AT THE REGtJEST O~ THE FOLLOW! NG PERSON: NAMS: BRIAN A MCCAL__L, ESQ ADO~ESS:. 150 E CIIE~TNUT ST TELEPHONE: SUPREME COURT ID # _ ATTORNEY FOR: I~CASTER, PA 17602 215-335-3212 DEFENDANT M302490-03 Seal'of the Oourt BY THE (X)URT: /3 /~ ' Peothor~mry/glerl~,' Civi 1 ~ivision Deputy (Eff. ~'/97 ) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODI~/N OF RECORDS FOR: SE~DLEHOSP ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THER3~PY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMORANDA, CORRESPONDENCE AND ANY AND ALL MEDICAL REPORTS A/qD BILLING INFORMATION FROM 6/1/01 TO PRESENT. PERTAINING TO: NAME: A/)DRESS: DATE 0F BIRTH: SSAN: S/%NDRA D WILLIAMS 9 S HUMER ST ENOLA Pa 09/09/52 179448562 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDS AREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. £ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X- I~AYS ( ) RECORDS XRAYS have been destroyed Date CUMBERLAND M302490-03 Authorized signature for SEIDLE HOSP *** SIGN AND RETURN THIS PAGE *** WILLIAMS Vs. DAVIDSON, & WILLIAMS ET AL 011025 ORIGINAL X-RAYS REQUESTED SUBPOENA TO PROOUCE DOCLX~ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 SEIDLE HOSP-X, 120 S FILBERT ST, MECHANICSBURG PA 17055-6591 TO: ___ ATTN: MEDICAL RECORDS DEPT __ (Name of Person or Entity) within twenty (20) days after service of this subpoena, you ere ordered by the court to produce the following docu~ent,~ or things: SEE Al IACHED ADDENDUM ..... at MEDICAL LEGAL REPRODUCTIONS~ATu~N~s~940 DISSTON ST., PHILA., PA You may deliver or mail legible cooies of the doct~ents or p~oduce things requested this subooena, to~ether with the certificate of co,wliance, to the party making thi~ request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the doctments or things required by this subpoena within twenty (20) days after its se~vlce, the party serving thi~ subpoena may seek a court order' o~,~elling you to co,~ly with it. TH I S SUBPOENA WAS NA~: ADORESS: ___ I SSU~ AT THE RE(~ST OF ~ FOLLOW IN~ PERSON: BRIAN A MCCALL, ESQ 150 E CHESTNUT ST TELEPHONE: SLIPR~ COURT ID # ATTORNEY FOR: iH~NCA~'I'~K, FA 17602 215-335-3212 DEFENDANT M302490-04 Sea~ of the~Dourt BY 'IFf CO JRT: ~/~~ ProthorW~tary/CJ~k, Ci¥~ oivisien Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: SEIDLEHOSP-X SPECIFICALLY **LIMITED** TO DIAGNOSTIC FILMS FROM 6/1/01 TO THE PRESENT. PERTAINING TO: NAME: SANDRA D WILLIAMS ADDRESS: 9 S HUMER ST ENOLA PA DATE OF BIRTH: 09/09/52 SSAN: 179448562 ORIGINAL X-RAYS REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-PAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERI~kND M302490-04 Authorized signature for SEIDLE HOSP-X *** SIGN AND RETURN THIS PAGE *** CC~4~DN~'rH OF FEt~ISYL~ O~J~ OF ~ WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL File No. 011025 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PROOUCEDOOJ~NTSORTHINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CAPITAL AREA CARDIO SURG, 423 N 21ST ST #301, (Name of Person o~ Entity) CAMP HILL PA 17011 Within twenty (20) days after service of this subpoena, you ere o~de~ed by the court to produ¢, th. fol lowing docu nt ors g iFrACI_lEu ADDENDUM at MEDICAL LEGAL REPRODUCTIONS(A~§s~940 DISSTON ST., PHILA., PA You msy deliver o~ mail legible co~ies of the documents o~ I~Oduce things re~ested b5 this sub--a, t~eth~ with the c~tificate of ~li~e, to the p~ty~kin9 thi[ r~est at the address lis~d ~ve. Y~ have the ri~t to s~k in advice the reac~n~l¢ cost of pre0~ing the ~ies or Or~ucing the things s~ght. If you fail to produce the doc~n~ts or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoenamay seek a court order' ~J,~ellin9 you to c~,wly with it. TH I S 9.,IBPO~NA WAS N,a4flE: ADORE,SS: ISSUED AT THE RE(ZJEST OF THE FOLLOWING PERSON: BRIAN A MCCALL, ESQ 150 ]? ilH]~STNUT ST TELEPHONE: SUPREME OOURT ID # ATTORNEY FOR: hANcASTER, PA 17602 215-335-3212 DEFENDANT M302490-05 DATE: ~.~,/,~- ~{- Jt~ Seat of the'~rt BY THE COURT: /'~ 4 Prot 1VlSlO~ Deputy (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: CAPITAL AREA CARDIO SURG ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THERAPY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMORANDA, CORRESPONDENCE AND ANY AND ALL MEDICAL REPORTS, DIAGNOSTIC FILMS AND BILLING INFO FROM 3/1/00 TO PRESENT. PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRAD WILLIAMS 9 S HUMER ST ENOLA PA o9/o9/52 179448562 ORIGINAL X-R3kYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X- RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M302490-05 Authorized signature for CAPITAL Ai{EA CARDIO SURG *** SIGN AND RETURN THIS PAGE *** COUNTY OF ~ WILLIAMS & WILLIAMS : Vs. . DAVIDSON, ET ~ File No. 011025 ORIGINAL X-PAYS REQUESTED MEDICAL BILLING REQUESTED SUSPC~NA TO PR(DUC~ DOOJ~ENTS OR THIN~S FOR DISOOVERY PURSUANT TO RULE 4009.22 DR FPJ%_NK DELEO, 3400 DERRY ST, HARRISBURG PA 17111 (Name of Person or Entity) Within twenty (20) days afte~ service of this subpoena, you ere erdered by the court to oroduce th. fo1 lowing doc~zent~SEE'~A' ADDENDUM MEDICAL LmGAL EEPRODUCTIOMScA~§s~940 DISSTOM ST., PEILA. , PA You may deliver or mail legible cooies of the docunents o~ produce things requested this subooe~a, tosether with the certificate of co,vliance, to the pa~ty making thi~ request at the ado~ess listed above. You have the right to seek in advance the rea~onabl~ cost of preparing the copies or producing the thin9s sought. If you fail to produce the doct~nts or things required by this subpoena within twenty days after its service, the party serving thin sJopoena may seek a court o~,~elling you to cc~ly with it. THIS ~IBPO~NA WAS I~SLI~D AT THE REQUEST O~ THE FOLLOWING PERSON: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: BRIAN A MCCALL, ESQ 1~0 E CHESTNUT ST hAi~UA$'I'~, PA 17602 215-335-3212 DEFENDD/~TT M302490-06 DATE: ..... C/J~M,~ ~ G ~thO,{ SealOof theC~::ourt Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: DR FRANK DELEO ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THERAPY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMORANDA, CORRESPONDENCE AND ANY D~ND ALL MEDICAL REPORTS, DIAGNOSTIC FILMS AND BILLING INFO FROM 2/1/00 TO PRESENT. PERTAINING TO: NAME: SANDRA D WILLIAMS ADDRESS: 9 S HUMER ST ENOLA PA DATE OF BIRTH: 09/09/52 SSAN: 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECOBDSAREATTACHED HEBETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X- RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M302490-06 Authorized signature for DR FRANK DELEO *** SIGN AND RETURN THIS PAGE *** c~TH OF pF/~NSYLVANIA O00NTY OF CUMR~D WILLIAMS & WILLIAMS : VS. : DAVIDSON, ET AL : File No. 011025 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PEOOUCE DOCLI~NTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: SUSQUEHANN VAL PAIN MGMT, 2025 TECHNOLOGY PKWY #201, MECHANICSBURG PA 1 (Name of Person o~ Entity) Within twenty (20) days after service of this subpoena, you a~e o~de~ed by the court to 0roduce the fol lowing doctm~t~ OrS g[ i. TACHED ADDENDUM at PA You may deliver or mail le9ible copies of the doctzrents or produce things requested this subpoena, together with the certificate of cu,wliance, to the party making thi~ request at the address listed above._ you have the right to seek in advance the rea~onabl~ cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the pa~ty serving thin subpoena may seek a court orde~- ~,~elling you to ~,~ly with it. TI-Il S SUBPOENA WAS I~ AT THE REQUEST OF THE FOLLOWING PERSON: NA~: BRIAN A MCCALL, ESQ ADORESS: 150 E ~.qmN~Tm ST TELEPHONE: SUPREME COURT I D ~__.. ATTORNEY FOR: LANCASTER, PA 17602 215-335-3212 DEFENDANT M302490-07 DATE: ~_~ JC ~m3 Sea~ of the ~ourt Prothor(otery~k~, Civil ~ivision ~%out y (Eff. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: SUSQUEHANN VAL PA~N MGMT ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THERAPY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMORANDA, CORRESPONDENCE AND ANY AND ALL MEDICAL REPORTS, DIAGNOSTIC FILMS AND BILLING INFO FROM 8/1/00 TO PRESENT. PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDP~AD WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN ]RECORDSAREATTACHED HEBETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): RECORDS X-RAYS ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed ~ate CUMBERLAND M302490-07 Authorized signature for SUSQUEH/LN-N VAL PAIN MGMT *** SIGN AND RETURN THIS PAGE *** COb~DNWEALTH Of: p~qSYLVANIA O3t~qTY OF ~ WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL File No. 011025 ORIGINAL X-RAYS REQUESTED SUBPO~NATO PRO~JC~DOCUP~NTS~BILLIN~ REQUESTED FOR O l SCOVERY PURSUANT TO RULE 4009.22 TO: CENTRAL PENNA SPINAL ASSO, 805 SIR THOMAS CT, (Name of Perso~ or Entity) HARRISBURG PA 17109 Within twenty (20) days afte~ service of this subpoena, you a~e oPde~ed by the court to produce the fo1 lowing doc~nent.~ or things: SEE ATTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS(A~T~ss~940 DISSTON ST., PHILA., PA You may delive~ o~ mail legible copies of the documents o~ p~oduce things requested b) this subpoena, togethe~ with the certificate of ccrrpliance, to the pa~ty making this request at the address listed above. You have the right to seek in advance the rea~onabl~ cost of preparing the copies or producing the things sought. If you fsi! to produce the documents o~ things required by this subpoena within twenty (20) days aften its se~vlce, the party serving thi~ subpoena may seek s court orde~- ccnDelling you to ~,ply with it. THIS SUBPOENA WAS ISSUED ATTHERE(;UESTOFTHEFOLLOWlNGPERSON: NAME: RRTAN A MCCALL, ESQ 150 E CHESTNUT ST TELFPHONE: SUPREME CO JRT ID # ATTOi~IEY FO~: LANCASTER, PA 17602 215-335-3212 DEFENDANT M302490-08 DATE Sea~ of the Court Prothomota~y/~k ? Civt l(jOivision Deputy (Elf. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: CENTRAL PENNA SPINAL ASSO ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THERAPY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMORANDA, CORRESPONDENCE AND ANY D/ND ALL MEDICAL REPORTS, DIAGNOSTIC FILMS A/~D BILLING INFO FROM 1/1/99 TO PRESENT. PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSD~N: SAN~DRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-P~AYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M302490--08 Authorized signature for CENTRAL PENNA SPINAL ASSO *** SIGN AND RETURN THIS PAGE *** c~TH OF' F~YLVANIA ODUN~Y OF CUM~FRLA~D WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL File No. 011025 ORIGINAL X-RAYS REQUESTED REQUESTED TO: REHAB MED ASSOCS, C/O DR JAY CHO, 5124 E TRINDLE RD MRONANICSBURG PA 17055 (Name of Person o~ Entity) within twenty (20) days afte~ service of this subpoena, yo~ a~e o~de~ed by the court to produce the following doc~nent.~ o~ things: SEE ATTACHED ADDENDUM ...... at MEDICAL LEGAL REPRODUCTIONS~A~C~SS~940 DISSTON ST., PHILA., PA You may delive~ o~ ~il legible copies of the documemts o~ p~oduce things requested this subpoena, togethe~ with the certificate of c~,~liance, to the pa~ty making thiz request at the add~ess listed above. You have the right to seek in advance the reasonable cost of pmepering the copies or producing the things sought. If you fei] to produce the doctrnents o~ things cequired by this subpoena within twenty (20) days afte~ its ser-v~ce, the pa~ty serving 'thin subpoena may seek a court o~de~- ~a,oeiling you to oa,~]y with it. TH I S SUBPOENA WAS ISSUED AT THE RE(ZJEST OF THE FOLLOW I NG PERSON: NAME: RRIAN A MCCALL, ESQ ADDRESS: 150 E CIIEST~UJT ST TELEPHONE: SUPREFE OOURT ID #__ AI-FORNEY FOR: LANCAS TER-~--D-~ 17602 215-335-3212 DEFENDA/qT M302490-09 DATE: {~,~u~ ~. ~t~3 Sea~ of the Court Division Deputy (Eff. 7/97) ADDENDUM FO SUBPOENA WILLIAMS & WILLIA~4S VS. DAVIDSON, ET AL No. 011025 CUSTODIAN' OF RECORDS FOR: REHAB MED ASSOCS ENTIRE MEDICAL RECORDS PILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THERAPY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMOR3kNDA, CORRESPONDENCE AND ANY AND ALL MEDICAL REPORTS, DIAGNOSTIC FILMS AND BILLING INFO FROM 4/1/01 TO PRESENT. PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDS AREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERL,~ND M302490.-09 Authorized signature for REHAB MED ASSOCS *** SIGN AND RETURN THIS PAGE *** CO~40N'~LTH O~ p~qN~"fLVANIA CUtmn'Y OF ~ WILLIAMS & WILLIAMS VS. DAVIDSON, ET AL File No. 011025 ORIGINAL X-RAYS REQUESTED BILLING REQII~STED FOR DISCOVERY PURSUANT TO RULE .4009.22 TO: DR KATHERINE GALLAGHER, 4076 MARKET ST, CAMP HILL PA 17011 (Nan~ of Person or Entity) Within twenty (20) days after service of this subpoena, you ere ordered by the court to p~oduce the fol lowing doc~nent.~ or things: SEE ATTACHED Al)DEmi)bM at MEDICAL LEGAL REPRODUCTIONS(A~S~940 DISSTON ST., PHILA., PA You may deliver o~ mail legible copies of the doozn~ts or produce things requested this subpoena, together with the certificate of cu,~liance, to the party making thiz request at the add~ess listed above. You have the right to seek in advance the rea~.onabl~ cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court c,..,,~.,elling you to c~,~,ly with it. THIS SUBPOENA WAS ISSLIEDATTHEREQUESTOFTHEFOLLOWINGPERSON: NAMe: BRIAN A MCCALL, ESQ ADORERS: 150 E CHESTNUT ST TELEPHONE SUPRE~'IE CCURT ATTORNEY FOR LAiNCAS'I'~, MA 17602 215-335-3212 DEFENDANT M302490-10 DATE: ~,~ Sea,of the ~ - Prothonotary/C,)~"~, Civ/1 DJ-vision Deputy (Eff. ?/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: DR KATHERINE GALLAGHER ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THER3kPY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMOR3LNDA, CORRESPONDENCE AND ANY AND ALL MEDICAL REPORTS, DIAGNOSTIC FILMS ~%ND BILLING INFO FROM 2/1/01 TO PRESENT. PERTAINING TO: NAME: SANDRA D WILLIAMS ~-DDRESS: 9 S HUMER ST ENOLA PA DATE OF BIRTH: 09/09/52 SSA/q: 179448562 ORIGINAL X-PAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-PAYS ( ) RECORDS XPAYS have been destroyed Date CUMBERLAlkrD M302490-10 Authorized sxgnature for DR KATHERINE GALLAGHER *** SIGN AND RETURN THIS PAGE *** cO--TH OF' p]~NSYLVANTA OOUNTY OF OO34R~IA~D WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 ORIGINAL X-RAYS REQUESTED TO BILLIN6~ REQUESTED FOR' DISCOVERY PURSUANT TO RULE 4009:22 TO: DR MARK GRUBB, C/O ORTHO INST OF PA, 875 POPLAR CHURCH RD CAMP HILL PA 17011 (Name of Person or Entity) Within twenty (20) days afte~ service of this subpoena, you a~e o~de~ed by the court tc th.____ at MEDICAL LEGAL REPRODUCTIONS(A~s~940 DISSTON ST., PRILA., PA You may deliver o~ mai] legible copies of the doct~nents or produce things requested this subpoena, to~ethe~ with the certificate of c~,~liance, to the pa~ty making request at the addl~ess listed above. You have the right to seek in advance the rea~onab]~ cost of preoa~'ing the copies or producing the things sought. If you fail to produce the doct~nts or things required by this subpoena within twenty (20) days after its service, the party serving thi-~ subpoena may seek a court orde~' cx~,~elling you to cu,uly with it, THIS SUBPOENA WAS ISSUED AT THEREQUESTOFTHEFCLLOWlNGPERSON: NAME: BRIAN A MCCALL, ESQ ADORESS: 1~0 E CHESTNUT ST TELEPHONE: SUPREPE O~JRT ID # ATTORNEY FOR: LAblCAS'I'~R, PA 17602 215-335-3212 DEFENDANT M302490-11 seallof the Court Protho~ota~y/~1%~l%, oi~i~ Divis Deputy (Eff. ~/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 011025 CUSTODIAN OF RECORDS FOR: DR MARK GRD~B ENTIRE MEDICAL RECORDS FILE, INCLUDING BUT NOT LIMITED TO RESULTS OF DIAGNOSTIC TESTING, PHYSICAL THERAPY RECORDS, NURSES' NOTES, OFFICE NOTES, MEMORANDA, CORRESPONDENCE AND ANY AND ALL MEDICAL REPORTS, DIAGNOSTIC FILMS AND BILLING INFO FROM 10/1/01 TO PRESENT. PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRAD WILLIAMS 9 S HUMER ST ENOLA Pa 09/09/52 179448562 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COI~IPLETE AND RETURN ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. £ ] NO DOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING X-RAYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M302490-11 Authorized signature for DR M_ARK GRUBB *** SIGN AND RETURN THIS PAGE *** WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL File No. 011025 SUBPOENA TO PROOUCE DOCLI~NTS OR TH I NaS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DLA SYSTEMS INTEGRATION, 2001 MISSION DR #2, ATTN: PERSONNEL DEPARTMENT (Name of Person o~ Entity) NEW CUMBERL/LND PA 17070 Within twenty (20) days afte~ service of this subooe~a, you a~e o~de~ed by the court to pr~ce the foll~i~ ~t~ ~ ' g { . , at PHILA., You may delive~ o~ mail legible copies of the ~ts o~ produce things requested bt this subpoena, togethe~ with the certificate of ccr~liance, to the party making this request at the add~ess )iated above. You have the right to seek in advance the reasonable cost of preoa~ing the copies or producing the things sought. tf you fail to produce the doctr~e~ts or things required by this subpoena within twenty (20) days afte~ its service, the pa~ty serving thin subpoena may seek a court o~de~- o:~,~eliing you to can'~ly with it. THIS SLI~PO~NA WAS I,~.~ED AT THE REQt~ST O~ TH~ FO~LOWIN~ PERSON: NA~: BRIAN A MCCALL, ESQ ADO~ESS: 120 E C~{ESTNUT ST TELEPHONE: SUPREt~ COURT ID (4 ATTORNEY FOR: LA_NCAS'r~R, FA 17602 215-335-3212 DEFENDANT M302490-12 DATE: ~,.~,,~ ~L ~ Seal, of the ~ou~t (Eff. 7/97) ADDENDUM TO SUBPOENA WILLIAMS & WILLIAMS Vs. DAVIDSON, ET AL No. 01.1025 CUSTODIAN OF RECORDS FOR: DLA SYS~I~MS INTEGRATION **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: SANDRA D WILLIAMS 9 S HUMER ST ENOLA PA 09/09/52 179448562 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN COMPLETE AND RETURN [ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. £ ] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ) RECORDS ( ) PATIENT BILLING ) X-P~AYS ( ) RECORDS / XRAYS have been destroyed Date CUMBERLAND M302490-12 ~t-~-0rized signature for DLA SYSTEMS INTEGRATION *** SIGN AND RETURN THIS PAGE *** MEDICAL LE G~4L .REPR OD UCTIONS, INC. Main Offwe Phone: (215) 335-3212 Jefferson Bldg., Suite 926 4940 Disston Street Fax: (215) 338-2980 1015 Chestnut Street Philadelphia, Pa. 19135 E-mail Address: legal~'nedleg, com Philadelphia, Pa 19107 ADDEm DLA SYSTEMS INTEGRATION COPY OF THE ENTIRE EMPLOYMENT/PERSONNEL FILE, INCLUDING BUT NOT LIMITED TO, EMPLOYMENT APPLICATIONS, RESUMES/ESSAYS, WORK EVALUATIONS, JOB DESCRIPTIONS, W-2S, ATTENDANCE RECORDS, DISCIPLINARY NOTICES, JOB EVALUATIONS, PAYROLL INFORMATION, BENEFITS INFORMATION AND ANY OTHER RECORDS AT ANY TIME. East Gate Center, 309 Fellowship Rd., Mt. Laurel, NJ 08054 625 Liberty ~venue, Suite 2800 CNG fower, Pittsb.rgh, Pa 15222 (800) 436-1479 MORGAN & WILKEN, P.C. BY: SCOTT W. MORGAN, ESQUIRE IDENTIFICATION NO. 36721 120 SOUTH STREET HARRISBURG, PA 17101-1210 (717) 236-7959 ATITORNEYS FOR PLAINTIFF SANDRA D. WILLIAMS and THOMAS WILLIAMS, h/w Plaintiffs AARON DAVIDSON V. Defendant JASON ALAN BRANDT, Additional Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 01-1025 Civil CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER TO SETTLE. DISCONTINUE AND END TO TIlE PROTHONOTARY: Kindly mark the above matter settled, discontinued and ended upon payment of your costs, only. MORGAN & WILKEN, P.C. DATED: September -~( ,2003 (~cott g'~ Morgan,~squire/ ~rttorn~y for Plainti~