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HomeMy WebLinkAbout10-4593f-lLLs1-`~1! ..rr 2a~o ~~~. ~ 2 ~~~ ~: 2 ~ William P. Douglas, Esq. Supreme Court I.D. ti37926 Douglas Law Ofj~ice 43 W. South St. Carlisle, PA 17013 Telephone (717) 243-1790_ Judy Becker and Randy Becker, h/h In the Court of Common Pleas of Plaintiffs Cumberland County, Pennsylvania vs Comcast, Inc. /Comcast of Pennsylvania/Maryland, Inc. One Comcast Center Philadelphia, PA 19103 No. 2010 - H593 Civil Term Tailwind Communications, Inc. 2509 Gettysburg Rd. Camp Hill, PA 17011 Timothy Hare 1529 Bankbury Way Chesapeake, VA 23322 Civil action law Defendants jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Buell: Please issue a writ of summons against the defendants, Comcast, Inc. /Comcast of Pennsylvania/Maryland, Inc.; Tailwind Communications, Inc. and Timothy Hare. _ William P. I Attorney date: July 12, 2010 {..'~ 1 ~~ ~:1 ,,.1 ~.1~ L..M1~TtI ~ F ~. ~y~ ~Ra.oo PA ~r,-y ~~' /5'// 1/~a ~~Dlv~ ~E~` .+` _r Commonwealth of Pennsylvani~« ~~~~ ~ 2 ~~~~ , ~ 2 ~ County of Cumberland eL+',, T~/ Judy Becker and Randy Becker, h/h In the Court of Common Pleas of Plaintiffs Cumberland County, Pennsylvania vs Comcast, Inc. /Comcast of Pennsylvania/Maryland, Inc. One Comcast Center Philadelphia, PA 19103 Tailwind Communications, Inc. 2509 Gettysburg Rd. Camp Hill, PA 17011 No. 2010 - 454 3 Civil Term Timothy Hare 1529 Bankbury Way Chesapeake, VA 23322 Civil action law Defendants Jury Trial Demanded Writ of Summons To: Comcast, Inc. /Comcast of Pennsylvania /Maryland, Inc.; Tailwind Communications, Inc.; and Timothy Hare You are hereby notified that Judy Becker and Randy Becker have brought an action against you. ~~~ ~b~~ Deputy P othonotary Date: July 12, 2010 William P. Douglas, Esq. Douglas Law Office 43 W. South St. Carlisle, PA 17013 717-243-1790 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r , r_. - Sheriff rl~)_._ _ $~~~,~ of ~u+ab ~,~ ~ T, ~~ , Jody S Smith ~ '~~ Chief Deputy ~ ,, ~~'~ L~~ ~~;i`,; ~ ~ `~i i ! t ~ -: Richard W Stewart ~_~ ~~~~ ~p~~ Solicitor c~Ffce ,r .,+es~:f:RIFr ~G ,~._ _ _.-s~i~, ~' : .. , Judy Becker (et al.) Case Number vs. Comcast of Pennsylvania/ Maryland, LLC (et al.) 2010-4593 SHERIFF'S RETURN OF SERVICE 07/29/2010 04:50 PM -Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on July 29, 2010 at 1650 hours, he was unable to serve a true copy of the within Writ of Summons, upon the within named defendant, to wit: Comcast, Inc./ Comcast of Pennsylvania/ Maryland, Inc. Tina Michaels, Supervisor for Comcast, Inc. refused service advising Deputies to contact their legal department for service. CT Corporation System is located at 116 Pine Street, Suite 320 Harrisburg, PA 17101. 08/04/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Comcast Inc./Comcast of Pennsylvania/ Maryland, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 08/10/2010 02:00 PM -Dauphin County Return: And now August 10, 2010 at 1400 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Comcast Inc./ Comcast of Pennsylvania/ Maryland, Inc. by making known unto Sandra Schwalm, Corporate Operations Specialist for Comcast Inc. c/o CT Corporation at 116 Pine Street, Suite 320, Harrisburg, PA 17101 its contents and at the same time handing to her personally the said true and correct copy of the same. 08/12/2010 01:30 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 12, 2010 at 1330 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit:Tailwind Communications, Inc., by making known unto James R. Balkovic, President of Tailwind Communications, Inc. at 2509 Gettysburg Road, Camp Hitl, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $84.94 August 13, 2010 !._. NOAH LINE, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuife Sheriff. Teleosoft, Inc. Mary Jane Snyder Real Estate Depu William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy JUDY BECKER, ET AL VS County of Dauphin COMCAST OF PENNSYLVANIA/MARYLAND LLC Sheriff s Return No. 2010-T-2648 And now: AUGUST 10, 2010 at 3:00:00 PM served the within WRIT OF SUMMONS upon COMCAST OF PENNSYLVANIA/MARYLAND LLC by personally handing to SANDRA SCHWALM 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at C/O CT CORP 116 PINE STREET SUITE 320 HBG PA 17101 OTHER COUNTY CASE # 20104593 CORPORATE OPERATIONS SPECIALIST Deputy: B HUNTER Plaintiff: JUDY BECKER, ET AL Sheriffs Costs: $41.25 8/10/2010 Out Of County Cost: before me tMis___. ~ day o A. o~D R DAU NCO COM ISSION F~~C,PIRES iST MOI4QAY JANUARY. 20 1~ So Answers, ~~~ Sheriff of Dauphin County, Pa. Sworn to and subs~i~d OF T FlLED-a '; GARY William P. Douglas, Esq. Supreme Court I.D. #37926 Douglas Law Office 43 W. South St. Carlisle, P:4 17013 Tclephvne (717) 243-1790 Judy Becker and Randy Becker, h/h Plaintiffs vs Comcast, Inc./ Comcast of Pennsylvania/ Maryland, Inc. One Comcast Center Philadelphia, PA 19103 Tailwind Communications, Inc. 2509 Gettysburg Rd. Camp Hill, PA 17011 Timothy Hare 1529 Bankbury Way Chesapeake, VA 23322 Defendants Praecipe Dear Mr. Buell: 31 P1ai 2: 3 0 PENNSfi`LV,ANA In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2010 -4593 Civil Term 4 Civil action law Jury Trial Demanded Attached for filing is the Plaintiff's proof of service r. William P. lsou Attorney for E s Date: July 28, 2010 lT srvvnia7u .?nrnivr??wcn? nrynr. ri ro rU O C`- o r, - :»oraNmert.-'set ?i: O Q Re53nded Ue!ive - iFndorsemen+ 1'Rea,,-!o,.. t] Q- I'll M TIMOTHY HARE a+ 9305'Ramblebrook 'Road a Baltimore MD 21326-1756 -3800-AL-Kj-LV,-1 -2-006 See Hevct??e fo, Instructions ¦ Complete items 1, 2, and S. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space perrnits. - ArticEW TIMOT9305 OK ROAD MORE, MD 21326-1756 BALTI Agent XX fX ? Addressee B. R by,(PrlnfedN ) Date of Delivery D. Is delivery address different from item 1? 134(es If YES, enter delivery address below: ? No 3. Sprvice Type Certified Mail press Mail Registered turn Rece ipt for Merchandise F ? Insured Mail D, T0. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number /t/1l1 vL7v uvvt 0717 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 JUDY BECKER and RANDY BECKER, h/w, Plaintiffs V. PLED-07,10F (1!7 7??7 -I ATI 13 FPS 2:23 PENNSYLVANIA Attorneys for Defendant: COMCAST, INC.1COMCAST OF PENNSYLVANIA/MARYLAND, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA CIVIL ACTION - LAW NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Stephen E. Geduldig, Esquire, Stephanie L. Hersperger, Esquire, and Thomas, Thomas & Hafer, LLP, as attorneys for Defendant, Comcast, Inc./Comcast of Pennsylvania/ Maryland, Inc. in the above-captioned matter, reserving our right to answer or otherwise plead to Plaintiffs' Complaint. Respectfully submitted, ?`!,) ll5 By: THOMAS, THOMAS & HAFER, LLP 849184.1 STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendant, Comcast, Inc./Comcast of Pennsylvania/Maryland, Inc. Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L Hersperger, Esquire E-mail: shersperger@tthlaw. corn Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 Attorneys for Defendant: FAX (717) 237-7105 COMCAST, INCJCOMCAST OF PENNSYLVANIA/MARYLAND, INC. JUDY BECKER and IN THE COURT OF COMMON PLEAS RANDY BECKER, h/w, OF CUMBERLAND COUNTY, PENNA Plaintiffs CIVIL ACTION -LAW V. NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing ENTRY OF APPEARANCE was served by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the 1-z>'*? day of September, 2010, on all counsel of record as follows: William P. Douglas, Esquire DOUGLAS LAW OFFICE 43 West South Street Carlisle, Pennsylvania 17013 Attorneys for Plaintiff Tailwind Communications, Inc. 2509 Gettysburg Road Camp Hill, Pennsylvania 17011 Defendant Mr. Timothy Hare 1529 Bankbury Way Chesapeake, Virginia 23322 Defendant THOMAS, THOMAS & HAFER, LLP Stephen E. Geduldig, 852337.1 Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@fthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg. Pennsylvania 17108-0999 FAX (717) 237-7105 r,r fir r'•,- :1.q?F ; D 13 PH2:29 curd ; ?. J 60UNTY PENN'cYLVANiA Attorneys for Defendant: COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC. JUDY BECKER and IN THE COURT OF COMMON PLEAS RANDY BECKER, h/w, OF CUMBERLAND COUNTY, PENNA Plaintiffs CIVIL ACTION - LAW V. NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED PRAECIPE AND RULE TO FILE A COMPLAINT TO THE PROTHONOTARY OF SAID COURT: Please issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days after service of the Rule or suffer a judgment of non pros. Respectfully submitted, 85A62.1 THOMAS, THOMAS & HAFER, LLP By: STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney- I.D. No. 78735 Attorneys for Defendant, Comcast, Inc./Comcast of Pennsylvania/Maryland, Inc. RULE NO, Q -i' 13 , 201o, RULE IS ISSUED AS ABOVE. Prothonotary Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 JUDY BECKER and RANDY BECKER, h/w, Plaintiffs V. COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF SAID COURT: Please file of record the attached Certificate of Service which served the Rule to File a Complaint upon Plaintiffs issued by the Prothonotary of Cumberland County on September 13, 2010, with regard to the above-captioned matter. F j'; FD-OFFICE OF TLI : 11o%!10TA,R t31?c p 20 i iI 2: 4t Attorneys for Defendant: COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA CIVIL ACTION - LAW NO. 2010-4593 CIVIL TERM Respectfully submitted, `b By: THOMAS, THOMAS & HAFER, LLP 855283.1 STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendant, Comcast, Inc./Comcast of Pennsylvania/Maryland, Inc. Stephen E. Geduldig, Esquire E-mail sgeduldig@tthlaw.com Attorney LD. No 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harnsburg, Pennsylvania 17108-0999 FAX (717) 237-7105 FILED-?`?'"c ? p Z2b CuMb- PEWti o d `11A Attorneys for Defendant: COMCAST, INC.1COMCAST OF PENNSYLVANIA/MARYLAND, INC. JUDY BECKER and IN THE COURT OF COMMON PLEAS RANDY BECKER, h/w, OF CUMBERLAND COUNTY, PENNA Plaintiffs CIVIL ACTION - LAVAL NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED PRAECIPE AND RULE TO FILE A COMPLAINT TO THE PROTHONOTARY OF SAID COURT: Please issue a Rule on Plaintiff to file a Complaint in the above case i'\rithin twenty(2o) days after service of the Rule or suffer a judgment of non pros. Respectfully submitted, °t Ccb Ica 851162.2 By: TRUE COPY FROM RECORD In Testimony wherecif, I here unto set my hand and the s® I of-said CPWP at Carlisle, Pa. This Y of , 20 L, Prot otary THOMAS, THOMAS & HAFER, LLP STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorne37 I.D. No. 78735 Attorneys for Defendant, Comcast, Inc./Comcast of Pennsylvania/Maryland, Inc. RULE NOW, G_j?- , 201o, RULE IS ISSUED AS ABOVE. QL Prothonotary- Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 JUDY BECKER and RANDY BECKER, h/w, Plaintiffs v. Attorneys for Defendant: COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA CIVIL ACTION - LAW NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF : PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certif3,, that a true and correct copy of the foregoing RULE TO FILE A COMPLAINT was served by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the day of September, 2010, on all counsel of record as follows: William P. Douglas, Esquire DOUGLAS LAW OFFICE 43 West South Street Carlisle, Pennsylvania 17013 Attorneys for Plaintiff Tailurind Communications, Inc. 2509 Gettysburg Road Camp Hill, Pennsylvania 17011 Defendant Mr. Timothy Hare 9305 Ramblebrook road Baltimore, Maryland 21326-1756 Defendant THOMAS, THOMAS & HAFER, LLP Stephen E. Geduldig, Esquire 85-2337.1 JUDY BECKER and IN THE COURT OF COMMON PLEAS RANDY BECKER, h/w, OF CUMBERLAND COUNTY, PENNA Plaintiffs CIVIL ACTION - LAW V. NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing PRAECIPE SERVING THE EXECUTED RULE TO FILE A COMPLAINT EXECUTED BY THE CUMBERLAND COUNTY PROTHONOTARY ON SEPTEMBER 13, 2010, was served by depositing the same in e United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the day of September, 2010, on all counsel of records as follows: William P. Douglas, Esquire DOUGLAS LAW OFFICE 43 West South Street Carlisle, Pennsylvania 17013 Attorneys for Plaintiff Tailwind Communications, Inc. 2509 Gettysburg Road Camp Hill, Pennsylvania 17011 Defendant Mr. Timothy Hare 9305 Ramblebrook road Baltimore, Maryland 21326-1756 Defendant THOMAS, THOMAS & HAFER, LLP Stephen E. Geduldig, Esquire y ~ BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E-Mail: blcronthal@margolisedelstein.com Attorneys for Defendant, Tailwind Communications, Inc. File# 21500.4-00024 JUDY BECKER AND RANDY BECKER VS. COMCAST, INC./COMCAST OF COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANLAIMARYLAND, INC., NO. 2010-4593 TAILWIND COMMUNICATIONS, INC., AND TIMOTHY HARE CIVIL ACTION-LAW JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Defendant, Tailwind Communications, Inc., in the above-referenced matter. MARGOLIS EDELSTEIN Date: ~ c~ to l 0 Barry A~Kronthal ID# 55672 3510 Trindle Road ~~ ,,,, Camp Hill, PA 17011 _~ 717-975-8114 ~~ o ~~ cn ~" .--.~:.. ~~ .-' ._~ r-~ --~ E .~ ._,.~ -~ ~ `~ . r~ ~c~ --~ ~ ~~ :~ "r'i ~n C::3 ~ ....r • ` CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have this ~ day of ~(it U~ , 2010, served a true and correct copy of the following upon the person(s) and in the manner indicated below: Service by First Class Mail. Postage Prepaid, Addressed as Follows: William Douglas, Esquire 43 W. South Street Carlisle, PA 17013 Steven Geduldig, Esquire PO Box 999 Harrisburg, PA 1.7108 Timothy Hare 1529 Bankbury Way Chesapeake, VA 23322 MARGOLIS EDELSTEIN By: Carol Moose M:\mdir\1 Penn National121500.4-00024 Becker v. Comcast\Pleadings\EOA.9-14-10.wpd FILE0,OFFiCE ROMANDO ZIRULNIK SHERLOCK & DEMILLE OF THE PROTHONOTARY BY: JOHN D. KEARNEY, ESQUIRE IDENTIFICATION NO.: 44207 2010 DEC -1 PM 12: 06 United Plaza 30 S. 17th Street, Suite 1730 CUMBERLAND I.YANUANTY Philadelphia, PA 19103 (215) 640-3115 Attorney for Defendant, Timothy Hare JUDY BECKER and RANDY BECKER, h/w COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs V. NO: 2010-4593 COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC. and TAILWIND COMMUNICATIONS, INC.and TIMOTHY HARE Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY.- Kindly enter my Appearance on behalf of Defendant, Timothy Hare, in the above-captioned matter. ROMANDO BY: DEMAND FOR JURY TRIAL TO THE PROTHONOTARY. & DEMILLE Defendant, Timothy Hare, demands a jury trial consisting of twelve (12) members, in the above-captioned matter. ROMANDO ZIRULNIK BY: J & DEMILLE ROMANDO ZIRULNIK SHERLOCK & DEMILLE BY: JOHN D. KEARNEY, ESQUIRE IDENTIFICATION NO.: 44207 United Plaza 30 S. 17th Street, Suite 1730 Philadelphia, PA 19103 (215) 640-3115 Attorney for Defendant, Timothy Hare OF THE PROTHONOTARY 2010 DEC -I Pty 1: 11 CUMBERLAND COUNTY PENNSYLVANIA JUDY BECKER and RANDY BECKER, h/w Plaintiffs V. COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC. and TAILWIND COMMUNICATIONS, INC.and TIMOTHY HARE Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2010-4593 PRAECIPE TO FILE COMPLAINT TO THE PROTHONOTARY.- Please enter a Rule upon Plaintiffs to file a Complaint within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. ROMANDO ZIRULNIK SHERLOCK & DEMILLE BY: for Defendant, 1Y HARE ROMANDO ZIRULNIK SHERLOCK & DEMILLE BY: JOHN D. KEARNEY, ESQUIRE IDENTIFICATION NO.: 44207 United Plaza 30 S. 17th Street, Suite 1730 Philadelphia, PA 19103 (215) 640-3115 Attorney for Defendant, Timothy Hare JUDY BECKER and RANDY BECKER, h/w Plaintiffs V. COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC. and TAILWIND COMMUNICATIONS, INC.and TIMOTHY HARE Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2010-4593 RULE TO FILE COMPLAINT AND NOW, this ko day ofleW*6" , 2010 a Rule is hereby granted upon Plaintiffs to file a Complaint herein within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. J PROTH NOTARY T BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 Facsimile: (717) 975-8124 E-Mail: bkronthal@margolisedelstein.com FILED-OFFICE OF TVHE P SOT ONOTAR;, DcC 10 PH 1: 13 2010 CUMBERLAND CO(.NT`° PENNSYLVANIA ittorneysfor Defendant, Tailwind Communications, Inc. File# 21500.4-00024 JUDY BECKER AND RANDY BECKER, Plaintiffs V. COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC., TAILWIND COMMUNICATIONS, INC., AND TIMOTHY HARE, Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-4593 CIVIL ACTION-LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a Rule upon Plaintiff to file a Complaint within twenty (20) days of service thereof or suffer the entry of a judgment of non pros. MARGOLIS LSTEIN Date: December 9, 2010 Barry A. Kfon'hflal ID# 55672 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 Attorney for Defendant, Tailwind Communications, Inc. CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that I have served a true and correct copy of the following upon the person(s) and in the manner indicated below: Service ¢v First Class Mail, Postage Prepaid, Addressed as Follows: William Douglas, Esquire 43 W. South Street Carlisle, PA 17013 Steven Geduldig, Esquire PO Box 999 Harrisburg, PA 17108 Timothy Hare 1529 Bankbury Way Chesapeake, VA 23322 MARGOLIS EDELSTEIN -? I By: Angel . Kelly Date: December 9, 2010 M:\xndir\l Penn Nationafi21500.4-00024 Becker v. ComcastTleadingsTraecipe-Rule to He Complaint.wpd a JUDY BECKER AND RANDY BECKER, Plaintiffs V. COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC., TAILWIND COMMUNICATIONS, INC., AND TIMOTHY HARE, Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-4593 CIVIL ACTION-LAW JURY TRIAL DEMANDED RULE AND NOW, this je-? y of 201 , upon Praecipe of Defendant Tailwind Communications, Inc., a Rule is hereby entered upon the Plaintiffs to file a Complaint within twenty (20) days after service of this rule or suffer the entry of a judgment of non pros. Zrotlionotary William P. Douglas, Esq. Supreme Court I.D. #37926 Douglas Law Office 43 W. South St. Carlisle, PA 17013 Telephone (717) 243-1790_ Judy Becker and Randy Becker, h / h Plaintiffs vs Comcast, Inc./ Comcast of Pennsylvania/ Maryland, Inc.; Tailwind Communications, Inc.; and Timothy Hare Defendants COMPLAINT NOTICE Civil action law Jury Trial Demanded 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 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 32 South Bedford Street Carlisle PA 17013 717-249-3166 FILED-OFFICE t.,r- 11F f?l%0TI-101 OTARy 2010 DEC 16 Phi 1= 2 P i"UMBERLANC COUNIT { In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2010 - 4593 Civil Term BY December 14, 2010 COMPLAINT 1. The plaintiff, Judy Becker, is an adult individual residing at 57 Hazel Lane, New Oxford, Adams County, Pennsylvania. 2. The plaintiff, Randy Becker, is an adult individual residing at 57 Hazel Lane, New Oxford, Adams County, Pennsylvania. 3. The defendant, Comcast, Inc./Comcast of Pennsylvania/ Maryland, Inc., with a business address at One Comcast Center, Inc., Phildelphia, Pennsylvania. This defendant shall herein after be referred to as `Comcast'. 4. The defendant, Tailwind Communication, Inc., is a corporation with a business address at 2509 Gettysburg Rd., Camp Hill, Cumberland County, Pennsylvania. This defendant shall hereinafter be referred to as 'Tailwind'. 4. The defendant, Timothy Hare, is an individual with an address of 1529 Bankbury Way, Chesapeake, Virginia, 23322, This defendant shall hereinafter be referred to as 'Hare'. 5. At all time relevant hereto the defendants Tailwind and Hare, had entered into a business relationship with defendant Comcast, to install cable for subscribers of Comcast in the New Oxford, Pennsylvania area . As a result they were acting as agents of the defendant Comcast and as agents of each other and were acting within the scope of their employment. 6. At all times relevant hereto the defendant Comcast, owned and operated the cable television system servicing the New Oxford area. 7. On or about July 12, 2008 the plaintiff Judy Becker went outside in her yard for the purposes of walking her dog. Unbeknownst to her the defendants had left a cable lying in her yard which was not visible to the plaintiff. 8. At all times relevant hereto the plaintiff Judy Becker was married to the plaintiff Randy Becker. Count 1-- ludo Becker v Defendants 9. Paragraphs 1 through 8 are incorporated herein and reference is made thereto. 10. After walking outside the plaintiff Judy Becker tripped over the wire that was left by the defendants of the aforesaid premises. 11. Due to the negligence of the defendants and through no fault of her own, the plaintiff Judy Becker, was injured. 12. The defendants were negligent in the following respects; a) in failing to warn the plaintiff of the perilous condition and trip hazard they created. b) in failing to remove the trip hazard they created in a timely manner. c) in failing to hire competent subcontractors to perform the work. d) in failing to inspect the area to ascertain that it was safe for public use. e) in failing to ascertain that the work was being performed in a safe and prudent manner. 13. As a direct and proximate result of the negligence of the defendants the plaintiff, Judy Becker, slipped and was injured. 14. As a result of the negligence of the defendants the plaintiff was injured. Her injuries include but are not limited to the following: a) in to her ankle and supporting structures. 15. As a result of her injuries the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future. 16. As a result of her injuries the plaintiff has incurred great pain and suffering and may continue to incur the same in the future. 17. As a result of his injuries the plaintiff has incurred aggravation and inconvenience, embarrassment and humiliation and a loss of life's pleasures, and may continue to incur the same in the future. 18. As a result of the injuries the plaintiff sustained on July 12, 2008 she has been permanently disfigured. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff, Randy Becker and against the defendants in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. Count 2 -- Randy Becker v Defendants 19. The allegations of paragraphs 1 through 18, are incorporated herein and reference is made thereto. 20. As a direct and proximate result of the injuries suffered by his wife the plaintiff hereby claims a loss of consortium as a result of her injuries, in that, said injuries have had a detrimental and substantial impact upon the marriage of the parties. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff, Randy Becker and against the defendants in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. December 14, 2010 Respectfully submitted, AFFIDAVIT I HEREBY SWEAR OR AFFIRM THAT THE FOREGOING IS TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND/OR INFORMATION AND BELIEF. THIS IS MADE SUBJECT TO THE PENALTIES OF 1S PA.C.S.§ 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DUE TO TIME CONSTRAINTS THIS AFFIDAVIT IS SIGNED BY COUNSEL FOR THE PLAINTIFFS. jL - December 14, 2010 -??L? ?p?y0N0 ARY ROMANDO ZIRULNIK SHERLOCK & DEMILLE BY: JOHN D. KEARNEY, ESQUIRE IDENTIFICATION NO. 44207 United Plaza 30 S. 17th Street, Suite 1730 Philadelphia, PA 19103-4008 (215) 640-3115 Attorney for Defendant, Timothy Hare JUDY BECKER and RANDY BECKER, h/w Ci3"???RLAND CpUN?`? PEl?!?SYI.VA?1 A COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs V. : NO: 2010-4593 COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC. and TAILWIND COMMUNICATIONS, INC. and TIMOTHY HARE Defendants DEFENDANT. TIMOTHY HARE'S ANSWER TO PLAINTIFFS' COMPLAINT WITH NEW MATTER AND NEW MATTER CROSSCLAIM 1. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 2. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 3. Denied. The averments contained in this paragraph of Plaintiffs' Complaint are addressed to Defendants other than Answering Defendant herein. Answering Defendant is, therefore, advised that no further answer is required to the averments contained therein. 4. Denied. The averments contained in this paragraph of Plaintiffs' Complaint are addressed to Defendants other than Answering Defendant herein. Answering Defendant is, therefore, advised that no further answer is required to the averments contained therein. 4. (5). Denied. Defendant does not reside at the stated address. His current address is 9305 Ramblebrook Road, Baltimore, Maryland. 5. (6). Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 6. Denied. The averments contained in this paragraph of Plaintiffs' Complaint are addressed to Defendants other than Answering Defendant herein. Answering Defendant is, therefore, advised that no further answer is required to the averments contained therein. 7. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 8. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. WHEREFORE, Answering Defendant demands judgment in his favor and against the Plaintiff and against other Defendants herein. COUNTI 9. Answering Defendant hereby incorporates by reference the answers given to paragraphs 1 through 8 inclusive as though same were set forth fully hereinafter. 10. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 11. Denied as a conclusion of law requiring no responsive pleading. By way of further answer, after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiff's Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 12. Denied. The allegations contained in this paragraph of Plaintiffs' Complaint are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleading. Strict proof of these averments is demanded at trial. 13. Denied as a conclusion of law requiring no responsive pleading. By way of further answer, after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiff's Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 14. Denied as a conclusion of law requiring no responsive pleading. By way of further answer, after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiff's Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 15. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 16. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 17. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. 18. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. WHEREFORE, Answering Defendant demands judgment in his favor and against the Plaintiff and against other Defendants herein. COUNT II 19. Answering Defendant hereby incorporates by reference the answers given to paragraphs 1 through 18 inclusive as though same were set forth fully hereinafter. 20. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph of Plaintiffs' Complaint and, therefore, Answering Defendant denies the allegations and strict proof thereof is demanded at the time of trial. WHEREFORE, Answering Defendant demands judgment in his favor and against the Plaintiff and against other Defendants herein. NEW MATTER By way of further answer, Answering Defendant avers the following New Matter: 21. If it is determined that Answering Defendant is liable on the Plaintiffs cause of action, Answering Defendant avers that Plaintiffs recovery should be eliminated or reduced in accordance with the Pennsylvania Comparative Negligence Act, 42 Pa. C.S.A. § 7102. 22. It is further averred that if Plaintiff suffered any injuries or damages as alleged, they were caused solely and primarily by Plaintiffs own carelessness, recklessness and negligence. 23. It is further averred by Answering Defendant that if Plaintiffs suffered any injuries or damages as alleged, said Plaintiffs by their own conduct assumed the risk of those injuries or damages. 24. It is further averred by Answering Defendant that the Plaintiffs cause of action is barred by the appropriate Statute of Limitations. 25. The injuries indentified in Plaintiffs' Complaint were not caused by the fall described therein. WHEREFORE, Answering Defendant demands judgment in his favor and against the Plaintiff and against other Defendants herein. NEW MATTER IN THE NATURE CROSSCLAIM PURSUANT TO PA. R.C.P. 1031.1 26. Pursuant to the provisions of Pennsylvania Rule of Civil Procedure 1031.1, Answering Defendant asserts that Co-Defendants, Comcast, Inc./Comcast Of Pennsylvania /Maryland, Inc., And Tailwind Communications, Inc., are alone liable or is jointly and severally liable or is liable over to Answering Defendant for contribution and/or indemnity, on the cause of action declared upon in Plaintiffs' Complaint, and, therefore, Co-Defendants, Comcast, Inc./Comcast Of Pennsylvania /Maryland, Inc., And Tailwind Communications, Inc., are hereby severed and joined as an Additional Defendant in this action. WHEREFORE, Answering Defendant demands judgment in his favor and against the Plaintiff and against other Defendants herein. ROMANDO ZIRULNIK SHERLOCK & DEMILLE BY: TIMOTHY HARE VERIFICATION I, JOHN D. KEARNEY, ESQUIRE, hereby state that I am the attorney for the Defendant in the within action and verify that the averments or denials of facts contained in the foregoing are true based upon my personal knowledge, information and belief. If the foregoing contains averments which are inconsistent in fact, I have been unable, after reasonable investigation, to ascertain which of the inconsistent averments are true, but do have knowledge and information sufficient to form a belief that one of them is true. This Verification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. JO D. KEARN , ESQ CERTIFICATE OF SERVICE I, JOHN D. KEARNEY, ESQUIRE, hereby certify that on the 17'h day of February, 2011, a true and correct copy of the foregoing Answer to Plaintiffs' Complaint with New Matter and New Matter Crossclaim was served by United States First Class Mail, postage prepaid, upon the following parties: William P. Douglas, Esquire Douglas Law Office 43 West South Street Carlisle, PA 17013 Stephen E. Geduldig, Esquire Thomas, Thomas & Hafer 305 North Front Street Sixth Floor, P. O. Box 999 Harrisburg, PA 17108 Barry A. Kronthal Esquire MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 ROMANDO ZIRULNIK SHERLOCK & DEMILLE BY: J n. KEARN , ESQ ?!?> Stephen E. Geduldig, Esquire E-mail: sgeduldig@tthlaw.com Attorney I.D. No. 43530 (717) 237-7119 Stephanie L. Hersperger, Esquire E-mail: shersperger@tthlaw.com Attorney I.D. No. 78735 (717) 255-7239 THOMAS, THOMAS & HAFER, LLP 305 North Front Street Post Office Box 999 Harrisburg, Pennsylvania 17108-0999 FAX (717) 237-7105 FI ..ryyE?0-7, yOF?1?CEyi (x;y 2011 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Defendant: COMCAST, INC.ICOMCAST OF PENNSYLVANIA/MARYLAND, INC. JUDY BECKER and IN THE COURT OF COMMON PLEAS RANDY BECKER, h/w, OF CUMBERLAND COUNTY, PENNA Plaintiffs . CIVIL ACTION - LAW V. NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED ANSWER OF DEFENDANT, COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC., TO DEFENDANT, TIMOTHY HARE'S NEW MATTER IN THE NATURE OF A CROSSCLAIM PURSUANT TO PA R.C.P. 10n1.1 26. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant, Comcast, Inc./Comcast of Pennsylvania/Maryland, Inc., respectfully requests your Honorable Court to dismiss Plaintiffs' Complaint without cost or judgment to it. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Y: 919718.1 STEPHEN E. GEDULDIG, ESQUIRE Attorney I.D. No. 43530 STEPHANIE L. HERSPERGER, ESQUIRE Attorney I.D. No. 78735 Attorneys for Defendant, Comcast, Inc./Comcast of Pennsylvania/Maryland, Inc. JUDY BECKER and IN THE COURT OF COMMON PLEAS RANDY BECKER, h/w, OF CUMBERLAND COUNTY, PENNA Plaintiffs : CIVIL ACTION -LAW V. : NO. 2010-4593 CIVIL TERM COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC.; TAILWIND COMMUNICATIONS, INC.;: and TIMOTHY HARE, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing ANSWER OF DEFENDANT, COMCAST, INC./COMCAST OF PENNSYLVANIA/MARYLAND, INC., TO THE NEW MATTER IN THE NATURE OF A CROSSCLAIM PURSUANT TO PA R.C.P. 1031.1 was served by depositing the sampjn the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the IEday of March, 2011, on all counsel of record as follows: William P. Douglas, Esquire DOUGLAS LAW OFFICE 43 West South Street Carlisle, Pennsylvania 17013 Attorneys for Plaintiff Barry A. Kronthal, Esquire MARGOLIS EDELSTEIN 351o Trindle Road Camp Hill, Pennsylvania 17011 Attorneys for Defendant, Tailwind Communications, Inc. John D. Kearney, Esquire ROMANDO ZIRULNIK SHERLOCK & DEMILLE 30 South 17th Street, Suite 1730 Philadelphia, Pennsylvania 19103 Attorneys for Defendant, Timothy Hare THOMAS, THOMAS & HAFER, LLP Stephen E. Geduldig, Esquire 852337.1 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA URIGINAL PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JUDY & RANDY BECKER -VS- TERM, CUMBERLAND CASE NO: 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ t, MARYLAND, INC, ET AL As a prerequisite to service of a subpoena for documents and things jp% uatt to Rule 4009.22 _ i •_ > C MCS on behalf of BARRY A. KRONTHAL, ESQ. 4.3 certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2011 MCS on bdalf of BARRY 1?'. KRONTHAL, ESQ. Attornty for DEFENDANT KADKINS@MARGOLISEDELSTEIN.COM MCS # 17209-L01 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: JUDY & RANDY BECKER -VS- COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 2010-4593 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: WILLIAM P. DOUGLAS, ESQ., PLAINTIFF COUNSEL JOHN DEVAULT KEARNEY, ESQ. MCS on behalf of BARRY A. KRON_THAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/03/2011 CC: BARRY A. KRONTHAL, ESQ WILLIAM P. DOUGLAS, ESQ. DOUGLAS, DOUGLAS, ET AL 43 WEST SOUTH STREET 21500.4-00024 MCS on behalf of BARRY A. KRONTHAL, ESQ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 CARLISLE, PA 17013 MCS # 17209-CO1 DE02 Ilk - I LOCATION NAME MARTIN FOOT & ANKLE APPLE HILL SURGICAL ASSOC. MCDONALD'S CORPORATION HARTFORD FINANCIAL SERVICES CHUBB INSURANCE TRAVELERS INSURANCE CO. BROADSPIRE SERVICES, INC. LIBERTY MUTUAL INSURANCE CO. >>> LOCATION LIST <<< RECORDS REOUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT WORKER COMPENSATION RECORDS WORKER COMPENSATION RECORDS WORKER COMPENSATION RECORDS WORKER COMPENSATION RECORDS INSURANCE PAGE: 1 MCS # 17209-COl DE02 CI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER vs. File No. 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MARTIN FOOT & ANKLE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group. Inc., 1601 Market Street, Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL- ESO ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 2 5 2011 Date: Seal of the Court BY THE COURT: rothonotary/Clerk, Civil Division Deputy 1.7209-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR MARTIN FOOT & ANKLE 1010 EICHFFBERGER STREET HANOVFR, PA 17331 RE: MCS # 17209-LO1 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security #: XXX-XX-7211 Date of Birth: 05-12-1957 Please provide entire medical, billing, and diagnostic file. including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans. CT scans. EEG's EKG's, EEG's. MRI's, and x-rays and all corresponding reports or, inventories, patient histories. questionnaires, intake forms, evaluations, assessments, statements of diagnosis/prognos;s, diagnostic testing interpretations, physical therapy records & chiropractic records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-LO1 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JUDY & RANDY BECKER TERM, CUMBERLAND -VS- CASE NO: 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2011 MCS on behalf of BARRY -A :,' KRONTHAL , ESQ. Attorney for DEFENDANT KADKINS@MARGOLISEDELSTEIN.COM MCS # 17209-L02 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER File No. 2010-4593 vs. COMCAST, INC/COMCAST OF PENNSYLVANIA/ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for APPLE LI L SURGICAL ASSO (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * 1* EE ATTACHED RIDER * * * * at The M C ro p lnc 1601 Market tre t, Snite 800 Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL ESO ADDRESS: 3510 T iNDLE ROAn CAMP HILL, PA 17011 TELEPHONE: (215) 246-own SUPREME COURT ID ATTORNEY FOR: Defendant NOV 25 2011 Date: Seal of the Court BY THE COURT: -- !dL II rothonotary/Clerk, Givil Division Deputy t 7?n4-m EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR APPLE HILL SURGICAL ASSOC. 25 MONUMENT ROAD SUITE 220 YORK, PA 174035053 RE: MCS # 17209-1_02 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security #: XXX-XX-7211 Date of Birth: 05-12-1957 Please provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EMG's, MRI's, and x-rays and all corresponding reports or inventories, patient histories, questionnaires, intake forms, evaluations, assessments, statements of diagnosis/prognosis, diagnostic testing interpretations, physical therapy records, chiropractic records, and all records from Dr. Keith Tyson. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-L02 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JUDY & RANDY BECKER TERM, CUMBERLAND -VS- CASE NO: 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. 4 ,a MCS pn- beh if of DATE:_11/25/2011 BARRY-A. I RQNTHAL , ESQ. Attorney foz' DEFENDANT KADKINS@MARGOLISEDELSTEIN.COM MCS # 17209-L03 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER vs. File No. 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MCDONALD'S CORPORATION (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The M Group. Inc 1601 Market Street, it 800, Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL ESO ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: 1)darid z AW,tI Prothonotary/Clerk, Civil Division NOV 2 5 2011 Date: Deputy Seal of the Court 17209-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR MCDONALD'S CORPORATION 2111 MCDONALD'S DRIVE HUMAN RESOURSES OAKBROOK, 1L 60521 RE: MCS # 17209-L03 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security #: XXX-XX-7211 Date of Birth: 05-12-1957 Any and all employment records., including applications, files, memoranda, compensation, time and attendance records. Please include personnel records, payroll and salary information. Supply all employee medical records including any disability, workers compensation, or incident reports and claims, applications, pre-employment physicals & tests, post hiring physical, & tests, resumes/essays, work evaluations, reviews, job descriptions, leave of absence documents, disciplinary notices, letter of termination, letter of resignation & benefits information. Store Location: 6040 York Rd. New Oxford. Pa. This should contain all records in your possession, all archived records. or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-L03 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JUDY & RANDY BECKER TERM, CUMBERLAND -VS- CASE NO: 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on?behf of DATE: 11/25/2011 -,_ BARRY-A-. `K*N' THAL , ESQ. Attorneyfor DEFENDANT KADKINS@MARGOLISEDELSTEIN.COM MCS # 17209-L04 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER vs. File No. 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARTFORD FINANCIAL SERVICES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group. Inc.. 1601 Market Street. it 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO ADDRESS: 3510 TRINDLE ROAD CAMP HILL. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 25 2011 Date: ??. f, '26?11 Seal of the Court BY THE COURT: ?lCl 1??Ve?? Prothonotary/Clerk, Civil Division Deputy , 17209-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HARTFORD FINANCIAL SERVICES P.O. BOX 958459 LAKE MARY, FL_ 32795 RE: MCS # 17209-L04 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security #: XXX-XX-7211 Date of Birth: 05-12-1957 Please provide entire workers compensation files, including but not limited to all medical records, claims, correspondence, documentation supporting plaintiff's claim, payments, including dates of payments, payee and reasons for payments. patient histories, questionnaires, intake forms, progress notes, office notes, doctor, notes, nurses notes, evaluations, assessments, medical/consultation reports, statements of diagnosis/prognosis, reports of diagnostic testing, diagrostic testing interpretations, diagnostic films, physical therapy records, chiropractic records, memoranda & any and all correspondence related to the care and treatment of plaintiff. File #20000719243, Claim #YAV01395C, DOL: 811012000. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-L04 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JUDY & RANDY BECKER -VS- COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 2010-4593 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2011 MCS on- belf of a q' - - BARkY.-A.":RRONTHAL, ESQ. Attorney for DEFENDANT KADKINSLMARGOLISEDELSTEIN.COM MCS # 17209-L05 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER vs. COMCAST, INC/COMCAST OF PENNSYLVANIA/ File No. 2010-4593 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CHUBB INSURANCE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group, Inc.- 1601 Market Street, Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: _Defendant NOV 2 5 2011 Date: 7'?Lz? /? c4// Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy 17209-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR CHUBB INSURANCE FOUR PENN CENTER 1600 JFK BLVD PHILADELPHIA, PA 19103 RE: MCS # 17209-LO5 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security #: XXX-XX-7211 Date of Birth: 05-12-1957 Please provide entire workers compersation files, including but not limited to all medical records, claims, correspondence, documentation supporting plaintiff's claim, payments, including dates of payments, payee and reasons for payments. patient histories, questionnaires, intake forms, progress notes, office notes, doctor notes, nurses notes, evaluations, assessments, medical/consultation reports, statements of diagnosis/prognosis, reports of diagnostic testing, diagnostic testing interpretations, diagnostic films, physical therapy records, chiropractic records, memoranda & any and all correspondence related to the care and treatment of plaintiff. File #2E000441527, Claim #000071639233PR000, DOL: 9/13/99. This should contain al- records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-LO5 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JUDY & RANDY BECKER TERM, CUMBERLAND -VS- CASE NO: 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2011 I MCS on balf of Ff BARRY Al... KRONTHAL, ESQ. Attorney for DEFENDANT KADKINS@MARGOLISEDELSTEIN.COM MCS # 17209-L06 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER vs. File No. 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for TRAVELER INSURANCE CO (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, Inc.- 1601 Market Street, Suite 800, Philadelphia PA-19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL ESO ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: -(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 2 5 2011 Date: %, 07ell Seal of the Court BY THE COURT: id Lam. Prothonotary/Clerk, Civil Division Deputy 17209-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR TRAVELERS INSURANCE CO. P.O. BOX 13933 READING, PA 19612 RE: MCS # 17209-LO6 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security #: XXX-XX-7211 Date of Birth: 05-12-1957 Please provide entire workers compensation files, including but not limited to all medical records, claims, correspondence, documentation supporting plaintiff's claim, payments, including dates of payments. payee and reasons for payments, patient histories, questionnaires, intake forms, progress notes, office/doctor/nurses notes, evaluations, assessments, medical/consultation reports, statements of diagnosis/prognosis, reports of diagnostic testing, diagnostic testing interpretations, diagnostic films, physical therapy records, chiropractic records, memoranda & any/all correspondence related to the care and treatment of plaintiff. File #3F000554623, Claim #145DMQ6127, DOL: 12/1/94. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-LO6 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JUDY & RANDY BECKER -VS- COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 2010-4593 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. .rIC-S pn--behalf of DATE: 11/25/2011 - ~ " BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT KADKINS@MARGOLISEDELSTEIN.COM MCS # 17209-L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER vs. File No. 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ BROADSPIRF SERVICES INC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street. Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL ESO ADDRESS: 3510 TRINDLE ROAD CAMP L , PA 17011 TELEPHONE: 121 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 2 5 2011 Date: 5?C . % Seat of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy 17209-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR BROADSPIRE SERVICES, INC. 5001 LOUISE DRIVE #102 MECHANICSBURG, PA 17055 RE: MCS # 17209-LO7 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security ##: XXX-XX-7211 Date of Birth: 05-12-1957 Please provide entire workers compensation files, including but not limited to all medical records, claims, correspondence, documentation supporting plaintiff's claim, payments, including dates of payments, payee and reasons for payments, patient histories, questionnaires, intake forms, progress notes, office/doctor/nurses notes, evaluations, assessments, medical/consultation reports, statements of diagnosis/prognosis, reports of diagnostic testing, diagnostic testing interpretations, diagnostic films, physical therapy records, chiropractic records, memoranda & any and all correspondence related to the care 8 treatment of plaintiff. File #4N000399044, Claim #OPHRN92C0173, COL: 9/9/92. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-LO7 SU10 s r CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JUDY & RANDY BECKER -VS- COMCAST, INC/COMCAST OF PENNSYLVANIA/ MARYLAND, INC, ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 2010-4593 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2011 MCS_-©n behalf of BARRY A. KJONTHAL, ESQ. Attorney for DEFENDANT KADKINS@MARGOLISEDELSTEIN.COM MCS # 17209-L08 DE11 ., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JUDY & RANDY BECKER vs. File No. 2010-4593 COMCAST, INC/COMCAST OF PENNSYLVANIA/ SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LIBERTY MUTUAL INSURANCE CO (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group, Inc. 1601 Market Street, Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BARRY A. KRONTHAL, ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NOV 2 5 2011 Date: 5" / , /. 'X// Seal of the Court BY THE COURT: ?wid?? .?uP11 Prothonotary/Clerk, Civil Division ?-? V- . ? N't Deputy 17209-08 v? EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LIBERTY MUTUAL INSURANCE CO. P. 0. BOX 100059 DULUTH, GA 30096 RE: MCS # 17209-L08 JUDY BECKER 57 HAZEL LANE OXFORD, PA 17350 Social Security #: XXX-XX-7211 Date of Birth: 05-12-1957 Date of Loss: 0711212008 Please provide any and all insurance records and PIP files including but not limited to medical records. Include all claims, correspondence documentation supporting plaintiff's claim, and investigative reports, payments including dates of payments, payee, and reasons for payments, patient histories, questionnaires, intake forms, progress notes, office/doctor/nurses notes, evaluations, assessments, medical/consultation reports, statements of diagnosis/prognosis, reports of diagnostic testing, diagnostic testing interpretations, diagnostic films, physical therapy records,, chiropractic records, memoranda & any and all correspondence related to the care and treatment of plaintiff. Policy #YAV10395C. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 17209-L08 SU10 William P. Douglas, Esq. Supreme Court I.D. X37926 Douglas Law Office 43 West South Street Carlisle, Pennsylvania 17013 Telephone (717) 243-1790_ Judy Becker and Randy Becker, h / h Plaintiffs vs Comcast, Inc. /Comcast of Pennsylvania /Maryland, Inc.; Tailwind Communications, Inc.; and Timothy Hare Defendants Dear Mr. Buell: ~'!= ~~ N~ F'R~3THc~i~lv1 "' ~QIZNOV 20 PM ~~ 2i ~;U PENNSY~ ~ AN p ~~Y In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2010 - 4593 Civil Term Civil action Iaw Jury Trial Demanded Praecipe to Settle and Discontinue Please mark the above captioned matter settled and discontinued with prejudice. William P. ougla Esq. Attorney for PI tiff Date: November 20, 2012