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HomeMy WebLinkAbout04-3528BRENDA M. ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. lW - 3$'.& CIVIL TERM JESSE D. EASA, Defendant : CIVIL ACTION - LAW : Jury Trial Demanded NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court our 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 BRENDA M. ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. ny- 3S? P' CIVIL TERM JESSE D. EASH, Defendant : CIVIL ACTION - LAW Jury Trial Demanded COMPLAINT TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW COMES the Plaintiff, Brenda M. Anderson, by and through her attorneys, COYNE & COYNE, P.C., and avers the following in support of this complaint: 1. Plaintiff, Brenda M. Anderson, is an adult individual residing at 475 Sample Bridge Road, Enola, Cumberland County, Pennsylvania. 2. Defendant, Jess Eash, is an adult individual residing at 288 Stumpstown Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. On September 12, 2002 at approximately 9:15 o'clock a.m., Plaintiff was traveling west on Hogestown Road, in Silver Spring Township, Cumberland County, Pennsylvania, driving a 1998 GMC Jimmy and was stopped and stationary behind another vehicle that was stopped for a vehicle which was making a turn into the Main Difference Place. 4. At the same time, the Defendant was operating a Chevrolet 3500 pickup truck while using and speaking on a cellular telephone and driving directly behind Plaintiff traveling west on Hogestown Road, Silver Spring Township, Cumberland County, Pennsylvania. 5. Defendant then failed to slow or stop his truck as he approached the stopped and standing line of traffic and Defendant's truck violently collided with the rear of Plaintiffs stopped vehicle. 6. As a result of the rear-end collision, Plaintiff was thrown violently against the interior of the vehicle and sustained serious injuries to her muscles, nerves, tendons, connective tissues, skin, bones and organs of her body, including but not limited to severe strain to the cervical and lumbar vertebrae and contiguous soft tissue, back pain and nerve shock. 7. As a result of the collision, Plaintiff suffered severe injuries to her body in the nature of pain in her back; jarring to her abdomen and back; stiffness in her neck, back and hips; pain down her legs; and mental anguish. 8. As a direct and proximate result of the collision and Defendant's negligent conduct, Plaintiff has suffered, and will suffer in the future, pain, agony, anxiety and inconvenience. 9. Additionally, the Plaintiff was rendered sick, sore, and disoriented, and was made to undergo mental anguish and physical pain from which she suffered; still suffers and will continue to suffer for an indefinite time in the future. 10. In order to treat and attempt to remedy the aforesaid injuries, Plaintiff has expended various sums of money for medicine, medical care and surgical operations, and therapy and she will be required to expend additional sums of money for the same purpose in the future. 11. As a result of Defendant's negligent conduct, Plaintiff was unable to fully engage in and enjoy the active and physical activities as she had enjoyed and engaged in prior to collision caused by Defendant's negligence and will continue so in the future. 12. As a result of Defendant's negligence, Plaintiff was unable to work for an indefinite period of time. 13. As a result of the collision, Plaintiff sustained damage to her vehicle. 14. At the time of the accident, the negligence of the Defendant consisted of the following: (a) failing to keep his vehicle under proper and adequate control; (b) failing to keep a careful and diligent watch on the road; (c) operating and using a cellular telephone while operating and driving a motor vehicle on a busy public roadway; (d) operating his vehicle too fast for conditions; (e) failing to keep a proper distance behind the plaintiff s vehicle; (f) failing to slow or to bring his/its vehicle to a stop so as to avoid the impact with the rear of plaintiff s stopped vehicle; (g) failing to comply with the provisions of Section 3310 of the Pennsylvania Motor Vehicle Code relating to the operation of motor vehicles, specifically as they relate to the aforesaid acts of negligence; and (h) such other acts or omissions as may be revealed in the course of discovery; or at the trial of this case. WHEREFORE, Plaintiff respectfully requests that this Court find in her favor and against Defendant in an amount in excess of the mandatory arbitration amount for this county, plus interest and court costs. -r- 6 Dated: r 7 Respectfully submitted: COYNE & CO_YNE, P.C. By: isa Marie Coyne a. Supreme Ct. o.53788 3901 Market St. Camp Hill, PA 17011 (717) 737-0464 Attorneys for Plaintiff VERMCATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unworn falsification to authorities under 18 Pa. C.S.A. §4904. Dated: " n "Q &,L {L??? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW E. MCGUIRE, E certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/20/2005 MCS on behalf of /W xa' MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT DE11-585512 5 9 5 6 4- L 0 1- COMMONWEALTH O EP P ENNS YLVAN SA COLJNTY O F CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON -VS- FRY COMMUNICATIONS, INC. TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER HOSPITAL PATHOLOGY HARRISBURG HOSPITAL MEDICAL RECORDS MICHAEL PECK, M.D. MEDICAL RECORDS JOHN S. RYCHAK, MD MEDICAL RECORDS TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MATTHEW E_ MCGUIRE, 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: 08/31/2005 MCS on behalf of CC: MATTHEW E. MCGUIRE, ESQ. - 185118 DEREK HURLBERT - 450068219001 MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC_ 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311438 5 9 5 6 4- C 0 3 COMMONWEAL'T'H OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HANOVER HOSPITAL (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: MATTHEW E. MCGUIRE. ESQ. ADDRESS: 150 S. WARNER ROAD SUITE 270 KING OF PRUSSIA. PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT:, Prothonotary/ erk, C t Di ision SiF i u M19 Date: a Deputy A/,rte r D" Seal of the Court 59564-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HANOVER HOSPITAL DEPARTMENT OF PATHOLOGY 300 HIGHLAND AVENUE HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all pathology reports and records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-581414 S 9 S G 4- L 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW E. MCGUIRE, 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. MCS on behalf of DATE: 09/20/2005 MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT DE11-585513 5 9 5 6 4- L 0 2 P ENN S YLVAN S A COMMONWEALTH OF, CUMBERLAND COUNTY OF, IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, -VS- CASE NO: 04-3528 FRY COMMUNICATIONS, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND PURSUANT HANOVER HOSPITAL PATHOLOGY HARRISBURG HOSPITAL MEDICAL RECORDS MICHAEL PECK, M.D. MEDICAL RECORDS JOHN S. RYCHAK, MD MEDICAL RECORDS TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R_ DORER, ESQ. MCS on behalf of MATTHEW E_ MCGUIRE, 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: 08/31/2005 MCS on behalf of CC: MATTHEW E. MCGUIRE, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact MATTHEW E. MCGUIRE, ESQ_ Attorney for DEFENDANT THE MCS GROUP INC_ 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311438 5 9 5 6 4- C 0-3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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: MATTHEW E. MCGUIRE. ESO. ADDRESS: 150 S. WARNER ROAD SUITE 270 KING OF PRUSSIA. PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: 7 Prothonotary/Clerk,/Civil 'vtsi n J c, Date: Deputy Seal of the Court 59564-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT ST. HARRISBURG, PA 171012099 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-580980 59564-T-02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON COURT OF COMMON PLEAS TERM, CUMBERLAND -vs- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW E. MCGUIRE, 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. MCS on behalf of DATE: 09/20/2005 MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT DE11-585514 5 9 5 6 4- L 0 3 P ENNS YLVZ-1.N =A C OMMONWEALT H C)17 COUNTY CDF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON -v5- FRY COMMUNICATIONS, INC. HANOVER HOSPITAL HARRISBURG HOSPITAL MICHAEL PECK, M.D. JOHN S. RYCHAK, MD A SUBPOENA TO RY PURSUANT T PATHOLOGY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TERM, CASE NO: 04-3528 1 TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ_ MCS on behalf of MATTHEW E. MCGUIRE, 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: 08/31/2005 MCS on behalf of CC: MATTHEW E. MCGUIRE, ESQ. - 185118 DEREK HURLBERT - 450068219001 MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311438 5 9 S 6 4- C 0 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MICHAEL PECK. M.D. (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: MATTHEW E. MCGUIRE. ES ADDRESS: 150 S. WARNER ROAD KING OF PRUSSIA. PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: ] Prothonotary/C erk,/C Civil DiVistJ-n ? ??r Deputy Date: [ l e, .ALL Y? Seal of the Court 59564-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR MICHAEL PECK, M.D. 3130 GRANVIEW ROAD BLDG. A HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-580°82 5 9 5 6 4- L 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW E. MCGUIRE, 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. MCS on behalf of DATE: 09/20/2005 MATTHEW E. MCGUIRE, ES Attorney for DEFENDANT DE11-585515 S9564-T-04 COMMONWEALTH O F P ENN S YLVAN = A COUNTY O F CUMBERLAND IN THE MATTER OF. COURT OF COMMON PLEAS ANDERSON -VS- FRY COMMUNICATIONS, INC. NOTICE OF INTENT TO SERVE A SUBPOENA I THINGS FOR DISCOVERY PURSUANT HANOVER HOSPITAL PATHOLOGY HARRISBURG HOSPITAL MEDICAL RECORDS MICHAEL PECK, M.D. MEDICAL RECORDS JOHN S. RYCHAK, MD MEDICAL RECORDS TERM, CASE NO: 04-3528 PRODUCE RULE 4 TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. RORER, ESQ. MCS on behalf of MATTHEW E. MCGUIRE, 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: 08/31/2005 MCS on behalf of CC: MATTHEW E. MCGUIRE, ESQ. - 185118 DEREK HURLBERT - 450068219001 MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311438 S9 55G-1:-(:!03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHNS RYCHAK. MD (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: MATTHEW E. MCGUIRE. ESQ. ADDRESS: 150 S. WARNER ROAD SUITE 270 KING OF PRUSSIA. PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil 'visio Date: n Deputy Seal of the Court 59564-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN S. RYCHAK, MD 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-580984 5 9 5 6 4- 1, 0 4 c, ? o m - - - N ? w O d 6 BRENDA M. ANDERSON, : IN THE COURT' OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-3528 CIVIL TERM JESSE D. EASH and FRY COMMUNICATIONS, INC., Defendants : CIVIL ACTION - LAW : Jury Trial Demanded NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court our 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 BRENDA M. ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-3528 CIVIL TERM JESSE D. EASH and FRY COMMUNICATIONS, INC. Defendants : CIVIL ACTION - LAW : Jury Trial Demanded AMENDED COMPLAINT TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW COMES the Plaintiff, Brenda M. Anderson, by and through her attorneys, COYNE & COYNE, P.C., and avers the following in support of this amended complaint: 1. Plaintiff, Brenda M. Anderson, is an adult individual residing at 475 Sample Bridge Road, Enola, Cumberland County, Pennsylvania. 2. Defendant, Jess Eash, is an adult individual residing at 288 Stumpstown Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Defendant, Fry Communications, Inc. is a Pennsylvania Corporation, with a registered office located at 115 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania with a principle place of business located at 800 West Church Street, Mechanicsburg, Cumberland County, Pennsylvania. 4. On September 12, 2002 at approximately 9:15 o'clock a.m., Plaintiff was traveling west on Hogestown Road, in Silver Spring Township, Cumberland County, Pennsylvania, driving a 1998 GMC Jimmy and was stopped and stationary behind another vehicle that was stopped for a vehicle which was making a turn into the Main Difference Place. 5. At the same time, the Defendant was operating a Chevrolet 3500 pickup truck while using and speaking on a cellular telephone and driving directly behind Plaintiff traveling west on Hogestown Road, Silver Spring Township, Cumberland County, Pennsylvania. 6. Defendant then failed to slow or stop his truck as he approached the stopped and standing line of traffic and Defendant's truck violently collided with the rear of Plaintiff's stopped vehicle. COUNT I: Brenda Anderson, Plaintiff v. Jesse D. Eash, Defendant 7. Paragraphs 1 through 6 are incorporated herein by reference. 8. As a result of the rear-end collision, Plaintiff was thrown violently against the interior of the vehicle and sustained serious injuries to her muscles, nerves, tendons, connective tissues, skin, bones and organs of her body, including but not limited to severe strain to the cervical and lumbar vertebrae and contiguous soft tissue, back pain and nerve shock. 9. As a result of the collision, Plaintiff suffered severe: injuries to her body in the nature of pain in her back; jarring to her abdomen and back; stiffness in her neck, back and hips; pain down her legs; and mental anguish. 10. As a direct and proximate result of the collision and Defendant's negligent conduct, Plaintiff has suffered, and will suffer in the future, pain, agony, anxiety and inconvenience. 11. Additionally, the Plaintiff was rendered sick, sore, and disoriented, and was made to undergo mental anguish and physical pain from which she suffered; still suffers and will continue to suffer for an indefinite time in the future. 12. In order to treat and attempt to remedy the aforesaid injuries, Plaintiff has expended various sums of money for medicine, medical care and surgical operations, and therapy and she will be required to expend additional sums of money for the same purpose in the future. 13. As a result of Defendants' negligent conduct, Plaintiff was unable to fully engage in and enjoy the active and physical activities as she had enjoyed and engaged in prior to collision caused by Defendants' negligence and will continue so in the future. 14. As a result of Defendants' negligence, Plaintiff was unable to work for an indefinite period of time. 15. As a result of the collision, Plaintiff sustained damage to her vehicle. 16. At the time of the accident, the negligence of the Defendants consisted of the following: (a) failing to keep his vehicle under proper and adequate control; (b) failing to keep a careful and diligent watch on the road; (c) operating and using a cellular telephone while operating and driving a motor vehicle on a busy public roadway; (d) operating his vehicle too fast for conditions; (e) failing to keep a proper distance behind the plaintiffs vehicle; (f) failing to slow or to bring his/its vehicle to a stop so as to avoid the impact with the rear of plaintiff's stopped vehicle; (g) failing to use due care under the circumstances; (h) failing to comply with the provisions of Section 3310 of the Pennsylvania Motor Vehicle Code relating to the operation of motor vehicles, specifically as they relate to the aforesaid acts of negligence; and (i) such other acts or omissions as may be revealed in the course of discovery; or at the trial of this case. WHEREFORE, Plaintiff respectfully requests that this Court find in her favor and against Defendant in an amount in excess of the mandatory arbitration amount for this county, plus interest and court costs. COUNT II: Brenda Anderson, Plaintiff v. Fry Communications, Inc., Defendant 17. Paragraphs 1 through 16 are incorporated herein by reference. 18. As a result of the rear-end collision, Plaintiff was thrown violently against the interior of the vehicle and sustained serious injuries to her muscles, nerves, tendons, connective tissues, skin, bones and organs of her body, including but not limited to severe strain to the cervical and lumbar vertebrae and contiguous soft tissue, back pain and nerve shock. 19. As a result of the collision, Plaintiff suffered severe: injuries to her body in the nature of pain in her back; jarring to her abdomen and back; stiffness in her neck, back and hips; pain down her legs; and mental anguish. 20. As a direct and proximate result of the collision and Defendant's negligent conduct, Plaintiff has suffered, and will suffer in the future, pain, agony, anxiety and inconvenience. 21. Additionally, the Plaintiff was rendered sick, sore, and disoriented, and was made to undergo mental anguish and physical pain from which she suffered; still suffers and will continue to suffer for an indefinite time in the future. 22. In order to treat and attempt to remedy the aforesaid injuries, Plaintiff has expended various sums of money for medicine, medical care and surgical operations, and therapy and she will be required to expend additional sums of money for the same purpose in the future. 23. As a result of Defendants' negligent conduct, Plaintiff was unable to fully engage in and enjoy the active and physical activities as she had enjoyed and engaged in prior to collision caused by Defendants' negligence and will continue so in the future. 24. As a result of Defendants' negligence, Plaintiff was unable to work for an indefinite period of time. 25. As a result of the collision, Plaintiff sustained damage to her vehicle. 26. Defendant, Jesse D. Eash, at the times and dates stated in this Complaint, was an employee, servant and agent of Defendant, Fry Communications, Inc. 27. At all times relevant herein on September 12, 2002, ,Defendant Jesse D. Eash was traveling between worksites and buildings as an employee, agent or servant of Defendant Fry Communications, Inc. while performing services within the scope of his employment with Defendant Fry Communications, Inc. 28. At all times relevant to this collision, Defendant, Jesse D. Eash, was acting within the scope and course of his employment with Defendant, Fry Communications, hic. 29. As an employee, servant and agent of Defendant, Fry Communications, Inc., Defendant, Jesse D. Eash, did negligently cause injuries and harm to Plaintiff, Brenda M. Anderson and her motor vehicle; to wit: (a) failing to keep his vehicle under proper and adequate control; (b) failing to keep a careful and diligent watch on the road; (c) operating and using a cellular telephone while operating and driving a motor vehicle on a busy public roadway; (d) operating his vehicle too fast for conditions; (e) failing to keep a proper distance behind the plaintiff s vehicle; (f) failing to slow or to bring his/its vehicle to a stop so as to avoid the impact with the rear of plaintiffs stopped vehicle; (g) failing to use due care under the circumstances; (h) failing to comply with the provisions of Section 3310 of the Pennsylvania Motor Vehicle Code relating to the operation of motor vehicles, specifically as they relate to the aforesaid acts of negligence; and (i) such other acts or omissions as may be revealed in the course of discovery; or at the trial of this case. 30. The negligence of Defendant, Jesse D. Eash, in causing the violent collision, described above, is imputed to his employer and master, Defendant, Fry Communicaitons, hic. under the doctrine of respondeat superior. WHEREFORE, Plaintiff, Brenda Anderson, respectfully requests that this Honorable Court find in her favor against Defendant, Fry Communications, Inc. in an amount in excess of the amount for mandatory arbitration in this jurisdiction, plus interest and docket costs. Dated:" 2 `Y - Respectfully submitted: COYNE & COYNE, P.C By.V L_ isa Marie Coyne P a. Supreme Ct. N .53788 3901 Market St. Camp Hill, PA 17011 (717) 737-0464 Attorneys for Plaintiff VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A. §4904. Dated: /-4 o y LA" 0,,dbw? C.T nJ ?7 ?? f,? ? r- T1 Y' j l`; r e, F-i r r'= ? ; ?' r;_j L =x i S-' 7.?; -tom ;. Y?= `gym c'' -? _ --r r? =? O BRENDA M. ANDERSON, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3528 CIVIL TERM JESSE D. EASH and : CIVIL ACTION - LAW FRY COMMUNICATIONS, INC. Defendants : Jury Trial Demanded CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that a true copy of the Amended Complaint was served this date upon the below-referenced individual at the below listed address by way of First Class Mail, U.S. Postal Service: Mr. Jesse D. Eash 288 Stumpstown Road Mechanicsburg, PA 17055 p V Q 2q" 01 COYNE & COYNE, P.C. BY: L VA MARIE COYNE ESQUIRE 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff N C) r Z7 `'. ym -i- w y. ? Ali. K ?J .l) SHERIFF'S RETURN - REGULAR CASE NO: 2004-03528 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ANDERSON BRENDA M VS EASH JESSE D HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon EASH JESSE D the DEFENDANT at 2020:00 HOURS, on the 27th day of July , 2004 at 288 STUMPSTOWN ROAD MECHANICSBURG, PA 17055 by handing to JESSE D EASH a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.66 Affidavit .00 Surcharge 10.00 .00 34.66 Sworn and Subscribed to before me this day of QoZG?R9 ?l A.D. rothono/ t??? So Answers: R. Thomas Kline 07/28/2004 COYNE & COYNE By: Deputy Sheri f MATTHEW E. MCGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON V. ATTORNEY FOR DEFENDANTS JESSE D. EASH & FRY COMMUNICATIONS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS INC. TRIAL BY JURY OF 12 DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above captioned matter on behalf of Defendants, Jesse D. Eash & Fry Communications, Inc. LAW OFFICE OF ROBERT J. MATTHEW E. McGUIRE, ESQUIRE Attorney for Defendants, Jesse D. Eash & Fry Corn munications, Inc. !-, r,> r::* .._` .LL __{ B t'tr'., ' r ca ° ? ?, ., „ __ ? . -:, ? ?, ? ,J,,.,, C..e ,. MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE ATTORNEY FOR DEFENDANTS JESSE D. EASH & FRY COMMUNICATIONS, INC. 150 South Warner Road, Suite 270 King of Prussia, PA 19406 610 687-8303 BRENDA M. ANDERSON CUMBERLAND COUNTY V. COURT OF COMMON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS, INC. TRIAL BY JURY OF 12 DEMANDED DEMAND FOR JURY TRIAL Twelve (12) members, exclusive of alternates, are hereby demanded by Defendants, Jesse D. Eash & Fry Communications, Inc., in the above captioned matter. LAW OFFICE OF ROBERcDADE MATTHEW E. McGUIRE, ESQUIRE Attorney for Defendants, Jesse D. Eash & Fry Communications, Inc 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS Respectfully submitted, CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff vs. Y TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Jesse D. Eash. The Defendant reserves the right to otherwise plead in this matter. ASSOCIATES Date: August 2004 Attorney for Defendant, Jesse D. Eash Identification No. 39126 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff vs. TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants CERTIFICATE OF SERVK;E Donald R. Doter, Esquire, hereby certifies that he is the attorney for the Defendant, Jesse D. Each, herein, and that he caused a true and correct copy of the; attached to be served by regular first class mail upon: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Fry Communications, Inc. 115 West Main Street Mechanicsburg, PA 17055 Date: August 26, 2004 Donald R. Dorer,`Esquire Attorney for Defendant, Jesse D. Eash ? C N d - ^ Yn ntiiz' s 4 ? . m i?'> O O c-n To The Plaintiffs: You are hereby notified to answer the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Matthew E. McGuire, Esquire MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON CUMBERLAND COUNTY V. COURT OF COMMON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS, INC. TRIAL BY JURY OF 12 DEMANDED DEFENDANT, FRY COMMUNICATIONS, INC. ANSWER, NEW MATTER AND NEW MATTER PURSUANT PENNSYLVANIA RULE OF CIVIL PROCEDURE 225 Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at 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 in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. Admitted 4. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. 5. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. 6. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. COUNTI 7. Answering Defendant incorporates by reference the answer to paragraphs 1 through 6 inclusive, as fully as though the same were here set forth at length. 8-16. The averments contained in this paragraph 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. WHEREFORE, Answering Defendant prays that Plaintiffs Complaint be dismissed with prejudice or that judgment be rendered wholly in favor of Answering Defendant. COUNT II 17. Answering Defendant incorporates by reference the answer to paragraphs 1 through 16 inclusive, as fully as though the same were here set forth at length. 18. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 19. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 20. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 21. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 22. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 23. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 24. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 25. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 26. Admitted 27. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. 28. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. 29. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. Moreover, 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 and therefore, Answering Defendant denies the allegations. 30. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. WHEREFORE, Answering Defendant prays that Plaintiffs Complaint be dismissed with prejudice or that judgment be rendered wholly in favor of Answering Defendant. NEW MATTER 31. Answering Defendant incorporates by reference the answer to paragraphs 1 through 30 inclusive, as fully as though the same were here set forth at length. 32. If it is judicially determined that the Plaintiff suffered any injuries and/or damages as a result of the accident as alleged in Plaintiffs Complaint then such damages were proximately caused by the negligence of Plaintiff herself. 33. The Plaintiffs Complaint fails to state a cause of action upon which relief can be granted. 34. Plaintiffs Complaint in Civil Action avers that Plaintiff sustained personal injuries in a motor vehicle accident, which occurred in Pennsylvania on September 12, 2002. 35. Pursuant to the Motor Vehicle Financial Responsibility Law of February 12, 1984, as amended, 75 PA C.S.A. 1701, et seq., Plaintiff is precluded from pleading, introducing into evidence or recovering the amounts of the coverages set forth in 75 PA C.S.A. 1711. 36. Answering Defendant claims all immunities and defenses provided by the Motor Vehicle Financial Responsibility Law of February 12, 1984. 37. Plaintiffs Complaint in Civil Action avers that Plaintiff sustained personal injuries on September 12, 2002. Answering Defendant claims all of the immunities and defenses provided by the Motor Vehicle Financial Responsibility Law of February 12, 1984. Pursuant to the Motor Vehicle Financial Responsibility Law of February 12, 1984, as amended, 75 Pa. C.S.A. 1701, et seq., Plaintiff is precluded from pleading or introducing into evidence or recovering the amounts of the coverages set forth. Plaintiffs action is barred or limited by the limited tort option of the Motor Vehicle Financial Responsibility Law of February 12, 1984, as amended, 75 Pa. C.S.A. 1701, et eq., as Plaintiff has not sustained a serious injury. 38. If applicable, Plaintiffs are precluded from recovering any first party benefits, workers compensation benefits or health care benefits under a program, group contract or other arrangement, paid or otherwise payable, in the context of this third party liability claim pursuant to 75 Pa. C.S.A. 1719. NEW MATTER PURSUANT TO Pa.R.C.P. 2252(d) 39. By way of further New Matter, Answering Defendant avers the following cause of action: 40. If Plaintiff suffered injuries or damages as alleged in the Complaint said injuries and damages were caused solely by the negligence and carelessness of Defendant, Jesse D. Eash who is solely liable, or jointly and/or severally liable, and/or liable over to Answering Defendant. 41. If Answering Defendant is held liable to ]Plaintiff for all or part of such injuries and damages as Plaintiff may have suffered, Defendant, Jesse D. Eash is liable to Answering Defendant by way of contribution and/or indemnity, contractually or otherwise. WHEREFORE, Answering Defendant demands judgment in its favor and against Defendant, Jesse D. Eash, for all sums paid by Answering Defendant to Plaintiff as a result of verdict or settlement and attorney's fees, costs and interest. LAW OFFICE OF ROBERT J. MATTHEW E. MCGUIRE, ESQUIRE Attorney for Defendant Fry Communications, 3'lll v?l Inc. Dated: !? VERIFICATION Matthew E. McGuire, Esquire, hereby states that lie is the attorney of record for defendant Fry Communications, Inc., in this action and verifies that statements made in the foregoing Answer With New Matter and New Matter Pursuant to 2252(d) are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Date: UPI Matthew E. McGuire, Esquire Attorney for Defendant, Fry Communications, Inc. CERTIFICATE OF SERVICE I, Matthew E. McGuire, Esquire hereby certify that a true and correct copy of the foregoing document was sent via First Class United States Mail, postage prepaid on August ij, 2004, to the following counsel: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 LAW OF-FICE OF ROBERT J. MATTHEW E. McOUIRE, Attorney for Defendant Fry Inc. 1 (l ' 1J I 1}f N c_ I. c`, V rn 5 .. J -< 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff vs. TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants ANSWER WITH NEW MATTER OF DEFENDANT, JESSE D. SASH, TO PLAINTIFFS' AMENDED COMPLAINT Admitted. 2. Admitted. Paragraph 3 pertains to Defendant, Fry Communications, Inc., as to which no response is required from Answering Defendant. 4.- 6. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §1029(e). COUNTI Paragraph 7 is an incorporation by reference paragraph as to which no response s required from Answering Defendant. 8.46. Denied. These paragraphs are generally denied pursuant to Pa. R.C.P. §1029(e). COUNT II 17.- 30. Paragraphs 17 - 30 pertain to Defendant, Fry Communications, Inc., as to which no response is required from Answering Defendant. WHEREFORE, the Defendant, Jesse D. Eash respectfully prays this Honorable Court to dismiss Plaintiff's Amended Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant, Jesse D Eash. NEW MATTER 31. Paragraphs 1 through 30 are incorporated herein by reference, and made a part hereof as if set forth in full. 32. Plaintiff's claims are barred in whole or in part by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, the Defendant, Jesse D. Eash respectfully prays this Honorable Court to dismiss Plaintiff's Amended Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant, Jesse D. Eash. Respectfully submitted, LAW OFFICES OF JACOBS & ASSOCIATES By: Donald R. Dorer, Esquire Attorney for Defendant: Identification No. 39126 Date: September 2. 2004 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff vs. TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants VERIFICATION I, Jesse D. Eash , verify that the statements made in the which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. A?/ Av6 1 Dated: Y? a7 o?0K)4 se D. Eash 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. EASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-35'28 Civil Term Plaintiff vs. TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant, Jesse D. Each, herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendant, Jesse D. Eash, to Plaintiff's Amended Com Ip aint to be served by regular first class mail upon: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Fry Communications, Inc. 115 West Main Street Mechanicsburg, PA 17055 Date: September 2, 2004 1 Lx, K IV-6vj- big Donald R. Dorer, Esquir Attorney for Defendant, sse D. Eash (') ? _N T - ? ° ?Ti 1 -: r r-' Vf fTl '-1 T..-. V3 r: i -pr-?? L7 ? - v <'? 'Jib 1 .. ? "'t' .. , , iy ?::v ? s 1 "TI ? '` SHERIFF'S RETURN - REGULAR CASE NO: 2004-03528 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ANDERSON BRENDA M VS EASH JESSE D CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon EASH JESSE D the DEFENDANT , at 0929:00 HOURS, on the 11th day of August 2004 at 288 STUMPSTOWN ROAD MECHANICSBURG, PA 17055 by handing to KRISTEN EASH, ADULT DAUGHTER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 8.14 Affidavit .00 Surcharge 10.00 .00 36.14 Sworn and Subscribed to before me this 31,4.0- day of ?cn,q L. j n? (9v ? A. D. a roth nota So Answers: R. Thomas Kline 08/12/2004 COYNE & COYNE By: Deputy Sheriff '? SHERIFF'S RETURN - REGULAR CASE NO: 2004-03528 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ANDERSON BRENDA M VS EASH JESSE D BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FRY COMMUNICATIONS INC the DEFENDANT , at 1453:00 HOURS, on the 2nd day of August 2004 at 800 W CHURCH ROAD MECHANICSBURG, PA 17055 by handing to MARY ROBERTS, CONTROLLER, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 7.40 Affidavit .00 Surcharge 10.00 .00 23.40 Sworn and Subscribed to before me this J/,.J day of a--v.,a y A. D. V?P4othonotary " So Answers R. Thomas Kline 08/12/2004 COYNE & COYNE By: /LA ? Deputy Sheriff COYNE & COYNE, P.C. Attorneys at Law 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 BRENDA M. ANDERSON, Plaintiff vs. .JESSE 1). F.ASH and FRY COMMUNICATIONS, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. NO. 04-3528 CIVII, TERM CIVIL ACTION- LAW : 3urv Trial Demanded CERTIFICATE OF SERVICE, OF SECOND AMENDED COMPLAINT 1, l..isa Marie CoynC, Lsyuirc, of Coyne & Coyne. P.C., hereby certify that true copy of ih:: Second Amendcd Complaint was served this date upon the below-referenced individuals in the below listed address by way of first class mail, postage pre-paid: Donald R. Doter, Esq. 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Matthew E. McGuire, Esq. Law Office of Robert .1. McDadc 150 South Warner Road, Suite 270 King ofPrussia, PA 19406 Respectfully submitted: COYNE 8 COYNL, P.C. Dated Lisa Marie Coyne Pa. Supreme Ct. Nk 5378E 3901 Market St. Camp Hill, PA 17011 (717) 737-0464 Attorneys' fbrplaintijj ' ??, ?, r+d.£-ti:. ? .:.:. C. 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff vs. TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants OF NEW MATTER PURSUANT TO PA R.C.P. 2252(D) OF DEFENDANT, FRY COMMUNICATIONS, INC. 39. Paragraph 39 is an incorporation by reference paragraph as to which no response is required from Answering Defendant. 40.41. Denied. These paragraphs set forth conclusions of law as to which no response required from Answering Defendant. Should any allegations therein be deemed factual in nature, said allegations are generally denied pursuant to Pa.R. C.P. 1029(e). Respectfully submitted, LAW4VICEB OyhACOBS,jc ASSOCIATES Attorney for Defendant, Jesse D. Eash Identification No. 3912.6 Date: September 15, 2004 4HB-00094 SAW OFFICES OF JACOBS & ASSOCIATES A4 SENATE AVENUE, SUITE 503 -7AMP HILL, PA 17011 CELEPHONE NUMBER: (717) 731-0988 YTTORNEY FOR DEFENDANT, JESSE D. EASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff VS. Y TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants VERIFICATION DONALD R. DORER, ESQUIRE, hereby states that he is the attorney for the Defendant in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to a olities. Liz DONALD R. DORER, ESQUIRE Attorney for Defendant, Jesse D. F,ash Dated: September 15, 2004 IHB-00094 ,AW OFFICES OF JACOBS & ASSOCIATES 14 SENATE AVENUE, SUITE 503 'AMP HILL, PA 17011 'ELEPHONE NUMBER: (717) 731-0988 1TTORNEY FOR DEFENDANT, JESSE D. EASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, Plaintiff VS. Jesse D. Eash and Fry Communications, Inc., Defendants No.: 04-3528 Civil Term TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Doter, Esquire, hereby certifies that he is the attorney for the Defendant, Jesse D. Each, herein, and that he caused a true and correct copy of the attached Answer of Defendant Jesse D. Eash to New Matter Pursuant to Pa.R.C.P 2252(d) of Defendant, Fry Communications, Inc. to be served by regular first class mail upon: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Date: September 15, 2004 Matthew E. McGuire, Esquire Law Office of Robert J. McDade 150 South Warner Road, Multe2'/u King of Prussia, PA' 1'94 6 / Donald R. Dorer, Esquire Attorney for Defendant, Jesse D. Eash ?1 N C'? c-> C-i a- ?? C'?? C`I ??i T/ cy ? - - _;, '?- ?,- - `+' . e -?" - s-- MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. CUMBERLAND COUNTY COURT OF COI\IlVION PLEAS NO. 04-3528 TRIAL BY JURY OF 12 DEMANDED WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance in the above captioned matter on behalf of Defendant, Jesse D. Eash. LAW OFFICE OF ROBERT J A4e?DADE By: MATTHEW E. cGUIRE, ESQUIRE Attorney for Defendant Fry Communications, Inc. Dated: September 14, 2004 C% E' ?J r c... J:- ? ?=. tC? HB-00094 AW OFFICES OF JACOBS & ASSOCIATES 14 SENATE AVENUE, SUITE 503 AMP HILL, PA 17011 ELEPHONE NUMBER: (717) 731-0988 .TTORNEV FOR DEFENDANT, JESSE D. EASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff Y TRIAL DEMANDED Vs. Jesse D. Eash and Fry Communications, Inc., Defendants MA C 1. Admitted. ll. 2. Admitted. 3. Paragraph 3 pertains to Defendant, Fry Communications, Inc., as to which no response is required from Answering Defendant. 4.- 6. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §1029(e) COUNT I 7. Paragraph 7 is an incorporation by reference paragraph as to which no respons is required from Answering Defendant. 8.-16. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. 1029(e). COUNT II 17. Paragraph 17 is an incorporation by reference paragraph as to which no response is required from Answering Defendant. 18.-25. Paragraphs 18 - 25 pertain to Defendant, Fry Communications, Inc., as to which no response is required from Answering Defendant. 26.-30. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §1029(e). WHEREFORE, the Defendant, Jesse D. Eash respectfully prays this Honorable Court to dismiss Plaintiff's Amended Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant, Jesse D Eash. NEW MATTER 31. Paragraphs 1 through 30 are incorporated herein by reference, and made a part hereof as if set forth in full. 32. Plaintiff's claims are barred in whole or in part by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, the Defendant, Jesse D. Eash respectfully prays this Honorable Court to dismiss Plaintiff's Amended Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant, Jesse D. Eash. Respectfully submitted, LAW 0VrgCF,8 qF Jty'OBS & ASSOCIATES onald R. Doter, Esquire Attorney for Defendant Identification No. 39126 Date: September 16, 2004 i4HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 114 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff vs. Y TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants VERIFICATION DONALD R. DORER, ESQUIRE, hereby states that he is the attorney for the Defendant in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. DONALD R. DORER, ESQUIRE Attorney for Defendant, Jesse D. Eash Dated: September 16, 2004 94HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, Plaintiff V5. Jesse D. Eash and Fry Communications, Inc., Defendants No.: 04-3528 Civil Term TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant, Jesse D. Each, herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendant Jesse D Eash to Plaintiff's Second Amended Complaint to be served by regular first class mail upon: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Date: September 16, 2004 Matthew E. McGuire, Esquire Law Officc of Robcrt J. McDade 150 South Warner Road, Suite 270 King of Prussia, PA '19,40 Donald R. Dorer, Esquii?6 Attorney for Defendant, Jesse D. Eash r, ?? ?:, ? ?:? L? (/7 r„Ti -6 ^_ fTir _ - ' ? ?'? f.. ? ? ? ' l__ Q7 . ?': l:_? -? f?l ? `T:J " OJ MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. V. '-UAIIIERLAND COUNTY JESSE D. EASH & COURT OF COMMON PLEAS FRY COMMUNICATIONS, INC. NO. 04-3528 TRIAL BY JURY OF 12 DEMANDED PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Please substitute the attached Verification of Richard Jones on be half ofDefendan t for the Verification of Matthew E. McGuire, Esquire filed with Defendant's Matter and New Matter/Crossclaim to Plaintfs, Complaint. Answer with New Dated: / 7/ 04141 LAW OFFICE OF ROBERT MATTHEW E. McG ESQ?iT? Attomey for Defendant Fry Communications, Inc. tcrtoao ?iNCS VERIFICATION on behalf of Fry Com that the munications, Inc, a party in this action, verifies statements made in the foregoing Answer with Aiew Matter to plaintiffs' Complaint are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the 18 Pa.C.S. Section 4904, relating to unsworn falsifcation to authorities. penalties of 0y Date a RNDtson? ?/ WT 09-3S7g FAY e-nmnq Fry mg2j? umcations, Inc. Anderson CERTIFICATE OF SERI,7ICE 1, Matthew E- McG, Esquire hereby certify that a true foregoing document was sentlvia First Class United States Mail po tagere to counsel: p of the P p id to o the following Dated: -T z r D Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 LAW FICE OF ROBIiRT J. AD MA ?THHEWEEx?-,ycGU- Attorney . IR] , ESQUIRE for Defendant Fry Communications, Inc. C7 0 (" 7 C. czo `Il ?' : .,.. ? o 9 ?n - , ? , r I -? Cl .? CI? -; I -n -?' C:-:. W ?' j "?-,} O 0 `t7 d:' _`' To The Plaintiffs: You are hereby notified to answer the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. Matthew luuu' ire, Esquire ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. UUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 04-3528 TRIAL BY JURY OF 12 DEMANDED DEFENDANT, FRY COMMUNICATIONS, INC. ANSWER, NEW MATTER AND NEW MATTER PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 2252(d) TO ]PLAINTIFF'S SECOND AMENDED COMPLAINT Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at 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 in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. 3. Admitted 4. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. 6. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs Complaint, and therefore, denies same and demands strict proof thereof at trial. COUNTI 7. Answering Defendant incorporates by reference the answer to paragraphs 1 through 6 inclusive, as fully as though the same were here set forth at length. 8-16. The averments contained in this paragraph 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. WHEREFORE, Answering Defendant prays that Plaintiffs Complaint be dismissed with prejudice or that judgment be rendered wholly in favor of Answering Defendant. COUNT II 17. Answering Defendant incorporates by reference the answer to paragraphs 1 through 16 inclusive, as fully as though the same were here set forth at length. 18. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 19. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 20. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 21. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 22. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 23. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are; accordingly denied and strict proof thereof is demanded at the trial of this case. 24. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the averments respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same are accordingly denied and strict proof thereof is demanded at the trial of this case. 25. Denied. Answering Defendant has no knowledge or means of ascertaining the truth or falsity of the avennents respecting the injuries, sufferings, and/or damages alleged to have been sustained by Plaintiff and the same axe accordingly denied and strict proof thereof is demanded at the trial of this case. 26. Admitted 27. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. 28. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. 29. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. Moreover, 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 and therefore, Answering Defendant denies the allegations. 30. Denied. The allegations contained in this paragraph are conclusions of law to which the Pennsylvania Rules of Civil Procedure require no responsive pleadings and are therefore denied. WHEREFORE, Answering Defendant prays that Plaintiffs Complaint be dismissed with prejudice or that judgment be rendered wholly in favor of Answering Defendant. NEW MATTER 31. Answering Defendant incorporates by reference the answer to paragraphs 1 through 30 inclusive, as fully as though the same were here set forth at length. 32. If it is judicially determined that the Plaintiff suffered any injuries and/or damages as a result of the accident as alleged in Plaintiffs Complaint then such damages were proximately caused by the negligence of Plaintiff herself. 33. The Plaintiffs Complaint fails to state a cause of action upon which relief can be granted. 34. Plaintiffs Complaint in Civil Action avers that Plaintiff sustained personal injuries in a motor vehicle accident, which occurred in Pennsylvania on September 12, 2002. 35. Pursuant to the Motor Vehicle Financial Responsibility Law of February 12, 1984, as amended, 75 PA C.S.A. 1701, et seg., Plaintiff is precluded from pleading, introducing into evidence or recovering the amounts of the coverages set forth in 75 PA C.S.A. 1711. 36. Answering Defendant claims all immunities and defenses provided by the Motor Vehicle Financial Responsibility Law of February 1:Z, 1984. 37. Plaintiffs Complaint in Civil Action avers that Plaintiff sustained personal injuries on September 12, 2002. Answering Defendant claims all of the immunities and defenses provided by the Motor Vehicle Financial Responsibility Law of February 12, 1984. Pursuant to the Motor Vehicle Financial Responsibility Law of February 12, 1984, as amended, 75 Pa. C.S.A. 1701, et seq., Plaintiff is precluded from pleading or introducing into evidence or recovering the amounts of the coverages set forth. Plaintiffs action is barred or limited by the limited tort option of the Motor Vehicle Financial Responsibility Law of February 12, 1984, as amended, 7.5 Pa. C.S.A. 1701, et sue., as Plaintiff has not sustained a serious injury. 38. If applicable, Plaintiffs are precluded from recovering any first party benefits, workers compensation benefits or health care benefits under a program, group contract or other arrangement, paid or otherwise payable, in the context of this third party liability claim pursuant to 75 Pa. C.S.A. 1719. NEW MATTER PURSUANT TO Pa.iR.C.P. 2252(d) 39. By way of further New Matter, Answering Defendant avers the following cause of action: 40. If Plaintiff suffered injuries or damages as alleged in the Complaint said injuries and damages were caused solely by the negligence and carelessness of Defendant, Jesse D. Eash who is solely liable, or jointly and/or severally liable, and/or liable over to Answering Defendant. 41. If Answering Defendant is held liable to Plaintiff for all or part of such injuries and damages as Plaintiff may have suffered, Defendant, Jesse D. Eash is liable to Answering Defendant by way of contribution and/or indemnity, contractually or otherwise. WHEREFORE, Answering Defendant demands judgment in its favor and against Defendant, Jesse D. Eash, for all sums paid by Answering Defendant to Plaintiff as a result of verdict or settlement and attorney's fees, costs and interest. LAW O COBER McDADE MATTHEW E. MaGUIRE, ESQUIRE Attorney for Defendant Fry Communications, to Inc. Dated: (I I( VERIFICATION Matthew E. McGuire, Esquire, hereby states that he is the attorney of record for defendant Fry Communications, Inc., in this action and verifies that statements made in the foregoing Answer With New Matter and New Matter Pursuant to 2252(d) are true and correct to the best of his knowledge, information and beliief. The undersigned understands that the statements therein are made subject to the penalties of 18?a C.S. Section 4904, relating to unsworn falsification to authorities. Date: d ?j V 1 Matthew E. McGuire \ Attorney for Defend& Communications, Inc. Esquire t, Fry CERTIFICATE OF SERVICE I, Matthew E. McGuire, Esquire hereby certify that a true and correct co foregoing document was sent via First Class United States Mail, postage prepaid to othehe following counsel: Lisa Marie Coyne, Esquire Coyne & Coyne ,P.C. 3901 Market Street Camp Hill, PA 17011 Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 LAW OFFICE OF MATTHEW E. McGI. ESQUIRE Attorney for Defendant ry Communications, Inc. Dated: p pG •" 4J 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff Vs. TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants ANSWER OF DEFENDANT, JESSE D. EASH, TO NEW MATTER PURSUANT TO PA.R.C.P. 2252(D) OF DEFENDANT, FRY COMMUNICATIONS, INC. TO PLAINTIFF'S SECOND AMENDED COMPLAINT 39. Paragraph 39 is an incorporation by reference paragraph as to which no response is required from Answering Defendant. 40.41. Denied. These paragraphs set forth conclusions of law as to which no response required from Answering Defendant. Should any allegations therein be deemed factual in nature, said allegations are generally denied pursuant to Pa.R.C.P. 1029(e). Respectfully D nald R. Dorer,Esquire Attorney for Defendant, Jesse D. Eash Identification No. 39126 Date: October 18, 2004 4H B-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE $03 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. SASH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Brenda M. Anderson, No.: 04-3528 Civil Term Plaintiff VS. TRIAL DEMANDED Jesse D. Eash and Fry Communications, Inc., Defendants VERIFICATION DONALD R. DORER, ESQUIRE, hereby states that he is the attorney for the Defendant in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. i YONALD R. DORER, ESQUIRE Attorney for Defendant, Jesse D. Eash Dated: October 18, 2004 04HB-00094 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT, JESSE D. EASH Brenda M. Anderson, Plaintiff VS. Jesse D. Eash and Fry Communications, Inc., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 04-3528 Civil Term TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant, Jesse D. Each, herein, and that he caused a true and correct copy of the attached Answer of Defendant Jesse D. Eash to New Matter Pursuant to Pa.R.C.P. 2252(d) of Defendant, Fry Communications Inc to Plaintiff's Second Amended Complaint to be served by regular first class mail upon: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Date: October 18, 2004 Matthew E. McGuire, Esquire Law Office of Robert J. McDade 150 South Wamer Roa uite 270 King of Prussia, PA 106 /l i i R. Dorer, Esquire Attorney for Defendant, Jesse D. Eash ?? _= :? ?> - . ?.., - ' -? ?, : ?l _? _ 4) '?`'' i . r? CYO. ?,. MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON V. JESSE D. EASH & FRY COMMUNICATIONS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 04-3528 TRIAL BY JURY OF 12 DEMANDED MOTION TO COMPEL PLAINTIFF'S ANSWERS TO INTERROGATORIES AND RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS Defendant, Fry Communications, Inc., by and through its attorneys, The Law Office of Robert J. McDade, requests that the Plaintiff be ordered to provide full, complete and verified answers to Interrogatories and responses to Request for Production of Documents, and in support of this Motion, Defendant avers as follows: This is a personal injury case wherein movant is the Defendant, Fry Communications, Inc. 2. On or about October 25, 2004, counsel for moving Defendant served Interrogatories and a Request for Production of Documents upon Lisa Marie Coyne, Esquire, counsel for Plaintiff, Brenda M. Anderson. A true and correct copy of that letter is attached hereto as Exhibit "A". 3. Plaintiff has failed to answer or object to Defendant's Interrogatories and Request for Production of Documents within thirty (30) days as required by Rule 4009(b)(2). 4. By correspondence dated December 9, 2004, counsel for Defendant advised counsel for Plaintiff that he would file the present Motion to Compel within ten days unless he received discovery responses from the Plaintiff. A true and correct copy of that letter is attached hereto as Exhibit "B". 5. Pursuant to Pa.R.C.P. 4019, this Court is empowered to enter an Order compelling Plaintiff to provide full and complete answers to Interrogatories and responses to requests for Production of Documents. WHEREFORE, Defendant, Fry Communications, Inc., respectfully requests that this Court enter an Order directing Plaintiff to provide full, complete and verified answers to Interrogatories and to produce the documents and things responsive to Defendant's Request for Production of Documents within thirty (30) days or suffer sanctions upon application to this Court. Respectfully submitted, LA=Mc cDADE MAIRE Attorney for Defen dant, Fry Communications, Inc. MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 04-3528 MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS On or about October 25, 2004, counsel for moving defendant, Fry Communications, Inc., served Interrogatories and a Requests for Production of Documents upon Plaintiff. Pursuant to Pa.R.C.P. 4005, 4006 and 4009.12, responses to said discovery requests were due within thirty days of service. To date, Defendant has not received answers or objections to the aforementioned discovery requests. Defendant cannot adequately prepare a defense to Plaintiff s claims unless the aforesaid Interrogatories and Requests for Production of Documents are answered. Accordingly, pursuant to Pa.R.C.P. 4019, Defendant respectfully requests that this Court enter an Order compelling Plaintiff to provide full and complete answers to Interrogatories and responses to Requests for Production of Documents within thirty days from the date of this Order. Respectfully submitted, LAW OFFICE OF ROBERT J. MATTHEW E. McGUIRE, ESQUIRE Attorney for Defendant, Fry Communications, Inc. Dated: L -?c 0 VERIFICATION Matthew E. McGuire, Esquire, hereby states that he is the attorney of record for defendant, Fry Communication, Inc., in this action and verifies that statements made in the foregoing Motion to Compel are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. LAW OFFICE OF ROBERT cDADE MATTHEW E. McGUIRE, ESQUIRE Attorney for Defendant, Fry Communications, Inc. MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 04-3528 ATTORNEY CERTIFICATION OF GOOD FAITH The undersigned counsel for Defendant, Fry Communication, Inc., hereby certifies and attests that he has made a good faith effort regarding the discovery matter contained in the foregoing discovery motion in an effort to resolve the specific discovery disputes at issue, and further, that despite all counsels' good faith attempts to resolve the disputes, they have been unable to do so without Court intervention. LAW OFFICE OF ROBERT J. McD? MATTHEW E. McGUIRE, ESQUIRE Attorney for Defendant, Fry Communications, Inc. Dated: ! Z., 3p p I CERTIFICATE OF SERVICE I, Matthew E. McGuire, Esquire, do hereby certify that a true and correct copy of the foregoing Motion to Compel was mailed via first class mail, postage prepaid to counsel listed below on Z1 , 2004: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 LAW OFFICE OF ROBERT J. Mc MATTHEW E. McGUIRL, ESQUIRE Attorney for Defendant, Fry Communications, Inc. EXHIBIT "A" r LAW OFFICE OF ROBERT J. McDADE Not a Partnership - Employees of a Member Company of Zurich North America WALNUT HILL PLAZA 150 SOUTH WARNER ROAD, SUITE 270 KING OF PRUSSIA, PA 19406 (610) 687-8303 FAX (610) 225-8160 ROBERT J. McDADE LISA BELLINO APELIAN MICHAEL W. CASEY WILLIAM E. DENGLER JOSEPH A. JULIANA October 25, 2004 Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 JEFFREY R. LIEBESMAN MATTHEW E. McGUIRE JEFFREY W. MEEHAN MARK A. MINICOZZI KAREN SHORT NORRIS RE: Anderson v. Fry Communications, Inc., et al Cumberland County Court of Common Pleas, No. 04-3528 Our Clients: Jesse D. Eash & Fry Communications, Inc. Date of Loss: 9/12/02 Dear Ms. Coyne: Enclosed please find Interrogatories and Request for Production of Documents addressed to the plaintiffs. Kindly respond to same in accordance with the Pennsylvania Rules of Civil Procedure. Very truly yours, LAW OFFICE OF ROBERT J. M ADE BY. MATTHEW E. McGUI Email: matthew.mcguire@zurichna.co Direct Dial: (610) 225-8167 MEM/caw Enclosure cc: Donald Dorer, Esquire Richard Jones, Fry Communications, Inc. Judianne M. Griffith, Claim Specialist, Zurich North America (Your File No.: 453-0068219-001) EXHIBIT "B" LAW OFFICE OF ROBERT J. McDADE Not a Partnership - Employees of a Member Company of Zurich North America WALNUT HILL PLAZA 150 SOUTH WARNER ROAD, SUITE 270 KING OF PRUSSIA, PA 19406 (610) 687-8303 FAX (610) 225-8160 ROBERT J. McDADE LISA BELLINO APELIAN MICHAEL W. CASEY WILLIAM E. DENGLER JOSEPH A. JULIANA December 9, 2004 Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 RE: Anderson v. Fry Communications, Inc., et al Cumberland County No. 04-3528 Our Client: Fry Communications, Inc. Date of Loss: 9/12/02 Dear Ms. Coyne: JEFFREY R. LIEBESMAN MATTHEW E. McGUIRE JEFFREY W.MEEHAN MARK A. MINICOZZI KAREN SHORT NORRIS On October 25, 2004 you were served with Interrogatories and Request for Production of Documents for answer by your client. To date, we have not received a response. Kindly provide your responses to said discovery requests within ten (10) days of the date of this letter in order to avoid the necessity of a Motion. Thank you. Very truly yours, LAW OFFICE OF ROBERT J. McDADE BY: U)LA V MATTHEW E. McGUIRE Email: matthew.mcguire@zurichna.com Direct Dial: (610) 225-8167 MEM:blm cc: Donald Dorer, Esquire Richard Jones, Fry Communications, Inc. Judianne M. Griffith, Claim Specialist, Zurich North America (Your File No.: 453-0068219-001) n 0 c Tl 71- Uri BRENDA M. ANDERSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JESSE D. EASH & FRY COMMUNICATIONS, INC., Defendant NO. 04-3528 CIVIL TERM ORDER OF COURT AND NOW, this 14ch day of January, 2005, upon consideration of Defendant Fry Communications, Inc.'s Motion To Compel Plaintiff's Answers to Interrogatories and Responses to Request for Production of Documents, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Lisa Marie Coyne, Esq. 3901 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Matthew E. McGuire, Esq.t 150 South Warner Road Suite 270 King of Prussia, PA 19406 Attorney for Defendant Fry Communications, Inc. Donald Dorer, Esq. % 214 Senate Avenue Camp Hill, PA 17011 Attorney for Defendant Jesse D. Eash J: Wesley Oler ., J. J :rc MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. COUNTY COURT OF COMMON PLEAS NO. 04-3528 TRIAL BY JURY OF 12 DEMANDED CERTIFICATE OF SERVICE I, Matthew E. McGuire, hereby certify that a true and correct copy of the January 14, 2005 Order of the Court setting for the a Rule Returnable within 20 days of service regarding the Motion to Compel Answers to Interrogatories and Request for Production of Documents of Defendant, Fry Communications, Inc., directed to Plaintiff has been served upon the following: Lisa Marie Coyne, Esquire Coyne & Coyne,P.C. 3901 Market Street Camp Hill, PA 17011 Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 Via: first class mail on the 25's day of January, 2005. LAW OFFICE OF ROBERT J. MCDADE l?4 MATTHEW E. McGUIRE, E RE Attorney for Defendant, Fry Communications, Inc. C` C.", ,,,. (lS; ?:`' ?'<-?( r'(. :; r? cc + x+ c? ?+-- N ?.1 R, n?,ir; , =i?.: ??? '. -'ci '\{'i t 1_t BRENDA M. ANDERSON, Plaintiff Vs. JESSE D. EASH and FRY COMMUNICATIONS, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3528 CIVIL TERM CIVIL ACTION - LAW Jury Trial Demanded ANSWER TO RULE TO SHOW CAUSE AND NOW COMES the Plaintiff, Brenda M. Anderson, by and through her attorneys, COYNE & COYNE, P.C., and avers the following in support of this Answer to Rule to Show Cause: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. By way of further response, on December 16, 2004, the undersigned counsel issued a written request for an extension to respond to the discovery request. A copy of the written request is attached as Exhibit "A". Attorney McGuire did not object to the written request for an extension until after the Motion to Compel was filed. Moreover, health limitations of counsel caused the delay in responding to discovery in the normal and customary manner that the undersigned counsel conducts herself. 5. Admitted. By way of further response, Answers to Interrogatories have been provided to counsel. Documents requested are being assembled for service upon counsel. WHEREFORE, Plaintiff respectfully requests that this Honorable Court deny Defendant, Fry Communications, Inc.'s Motion to Compel as Discovery has been provided and furthermore, Plaintiff's counsel had requested an extension within which to answer discovery to which Defendant, Fry Communications, Inc.'s counsel did not object nor did he indicate a refusal of the extension prior to filing the Motion to Compel. Respectfully, submitted: COYNE & COYNE, P.C. i Dated: Sy: Li Marie Coyne Supreme Ct. . 53788 3901 Market St. Camp Hill, PA 17011 (717) 737-0464 Attorneys for Plaintiff COYNE & COYNE, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne Lisa Marie Coyne Austin F. Grogan Sharon F. Clark 3901 Market Street Camp Hill, Pennsylvania 17011-4227 (717) 737-0464 Facsimile (717) 737-5161 Donald R. Doter, Esq. Jacobs & Associates 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Matthew E McGuire, Esq. Law Office of Robert J. McDade 150 South Warner Road, Suite 270 King of Prussia, PA 19406 Gentlemen: December 16, 2004 Re: Anderson v. Eash and Fry Communications. Inc. Cumberland County No. 04-3528 I received this date Attorney Dorer's discovery packet. Although I had Mr. McGuire's discovery packet, I was waiting for Attorney Dorer's discovery packet to prepare a collective response and assemble documents with minimum duplication of efforts. I will work with Ms. Anderson to prepare the discovery responses and have those to you as soon as possible, but no later than end January considering the holiday limitations. I am hopeful that this reasonable accommodation will be acceptable to both of you. If not, please let me know. With best personal wishes to you, I remain- Very truly yours, COYNE & COYNE, P.C. /5y Lisa Marie Coyne LMC/cmc Cc: Ms. Brenda Anderson, w/encls. CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Answer to Rule to Show Cause was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Donald R. Dorer, Esq. Jacobs & Associates 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Matthew E McGuire, Esq. Law Office of Robert J. McDade 150 South Warner Road, Suite 270 King of Prussia, PA 19406 Dated: sa Marie Co e v t 1 MATTHEW E. MCGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. IBERLAND COUNTY rRT OF COMMON PLEAS 04-3528 TRIAL BY JURY OF 12 DEMANDED MOTION TO COMPEL PLAINTIFF'S RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS Defendant, Fry Communications, Inc., by and through its attorneys, The Law Office of Robert J. McDade, requests that the Plaintiff be ordered to provide full and complete responses to Request for Production of Documents, and in support of this Motion, Defendant avers as follows: This is a personal injury case wherein movant is the Defendant, Fry Communications, Inc. 2. On or about October 25, 2004, counsel for moving Defendant served Interrogatories and Request for Production of Documents upon Lisa Marie Coyne, Esquire, counsel for Plaintiff, Brenda M. Anderson. A true and correct copy of that letter is attached hereto as Exhibit "A". On February 10, 2005, counsel for Plaintiff provided Answers to Interrogatories and indicated that the Plaintiff was undergoing a surgical procedure and that counsel was attempting to gather the medical records. A true and correct copy of that letter is attached hereto as Exhibit `B 4. To date, Plaintiff has failed to answer or object to Defendant's Request for Production of Documents within thirty (30) days as required by Rule 4009(b)(2). By letter dated April 19, 2005, inquiry was again made as to the status of Plaintiff's response to Defendant's Request for Production of Documents. A true and correct copy of that letter is attached hereto as Exhibit "C". 6. Finally by letter dated May 12, 2005, counsel for moving Defendant advised counsel for Plaintiff that he would file the present Motion to Compel within ten days unless he received discovery responses from the Plaintiff. A true and correct copy of that letter is attached hereto as Exhibit "D". 7. Pursuant to Pa.R.C.P. 4019, this Court is empowered to enter an Order compelling Plaintiff to provide full and complete responses to requests for Production of Documents. WHEREFORE, Defendant, Fry Communications, Inc., respectfully requests that this Court enter an Order directing Plaintiff to provide full and complete responses to Request for Production of Documents within twenty (20) days or suffer sanctions upon application to this Court. Respectfully submitted, LAW OFFICE OF Attorney for Defendant; Fry Communications, Inc. MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. IBERLAND COUNTY RT OF COMMON PLEAS 04-3528 MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS On or about October 25, 2004, counsel for moving defendant, Fry Communications, Inc., served Interrogatories and a Requests for Production of Documents upon Plaintiff. Pursuant to Pa.R.C.P. 4005, 4006 and 4009.12, responses to said discovery requests were due within thirty days of service. To date, Defendant has not received answers or objections to the Request for Production of Documents. Defendant cannot adequately prepare a defense to Plaintiff s claims unless the aforesaid Requests for Production of Documents are answered. Accordingly, pursuant to Pa.R.C.P. 4019, Defendant respectfully requests that this Court enter an Order compelling Plaintiff to provide full and complete responses to Requests for Production of Documents within twenty days from the date of this Order. Respectfully submitted, LAW OFFICE OF ROBERT Attorney for Defendant, Fry Communications, Inc. Dated: (j VERIFICATION Matthew E. McGuire, Esquire, hereby states that he is the attorney of record for defendant, Fry Communication, Inc., in this action and verifies that statements made in the foregoing Motion to Compel are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. § 4404, relating to unsworn falsification to authorities. LAW OFFICE OF ROBERT J. cD E MATTHEW E. McGU , ESQUIRE Attorney for Defendant, Fry Communications, Inc. MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON CUMBERLAND COUNTY V. COURT OF COMMON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS, INC. ATTORNEY CERTIFICATION OF GOOD FAITH The undersigned counsel for Defendant, Fry Communication, Inc., hereby certifies and attests that he has made a good faith effort regarding the discovery matter contained in the foregoing discovery motion in an effort to resolve the specific discovery disputes at issue, and further, that despite all counsels' good faith attempts to resolve the disputes, they have been unable to do so without Court intervention. LAW OFFICE OF ROBERT J. McDADE MATTHE C UlI2E Attorney for Defendant, ant, / Fry Communications, Inc. Dated: C9 CERTIFICATE OF SERVICE I, Matthew E. McGuire, Esquire, do hereby certify that a true and correct copy of the foregoing Motion to Compel was mailed via first class mail, postage prepaid to counsel listed below on JuneV?005: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 LAW OFFICE OF ROBERT J. c E MATTHEW E. McGUIRE, ESQUIRE Attorney for Defendant, Fry Communications, Inc. LAW OFFICE OF ROBERT J. McDADE Not a Partnership - Employees of a Member Company of Zurich North America WALNUT HILL PLAZA 150 SOUTH WARNER ROAD, SUITE 270 KING OF PRUSSIA, PA 19406 (610) 687-8303 FAX (610) 225-8160 ROBERT J. McDADE LISA BELLINO APELIAN MICHAEL W. CASEY WILLIAM E. DENGLER JOSEPH A. JULIANA October 25, 2004 Lisa Marie Coyne, Esquire Coyne & Coyne,P.C. 3901 Market Street Camp Hill, PA 17011 JEFFREY R. LIEBESMAN MATTHEW E. McGUIRE JEFFREY W. MEEHAN MARK A. MINICOZZI KAREN SHORT NORRIS RE: Anderson v. Fry Communications, Inc., et al Cumberland County Court of Common Pleas, No. 04-3528 Our Clients: Jesse D. Eash & Fry Communications, Inc. Date of Loss: 9112102 Dear Ms. Coyne: Enclosed please find Interrogatories and Request for Production of Documents addressed to the plaintiffs. Kindly respond to same in accordance with the Pennsylvania Rules of Civil Procedure. Very truly yours, LAW OFFICE OF ROBERT J. BY: MATTHEW E. Mc Email: matthew.mcguire@zu Direct Dial: (610)225-8167 MEM/caw Enclosure cc: Donald Dorer, Esquire Richard Jones, Fry Communications, Inc. Judianne M. Griffith, Claim Specialist, Zurich North America (Your File No.: 453-0068219-001) EXHIBIT "B" COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne Lisa Mane Coyne Austin F. Grogan Sharon F. Clark 3901 Market Street Camp Hill, Pennsylvania 17011-4227 717-737-0464 Fax: 717-737-5161 Donald R. Dorer, Esq. 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 February 10, 2005 Matthew E. McGuire, Esq. Law Office of Robert J. McDade 150 South Warner Road, Suite 270 King of Prussia, PA 19406 Re: Anderson v. Eash, et al. Dear Gentlemen: Enclosed is my client's Answers to Interrogatories. Ms. Anderson is undergoing a third surgical procedure on her back on February 15, 2004. I am attempting to collect all the medical records and will forward same under separate cover. Also enclosed is our Answer to the Rule to Show Cause per Mr. McGuire's undertaking. Thank you for your consideration. Very truly yours, COYNE & COYNE, P.C. d Marie Coyne / LMC/cmc Encl. Cc: Ms. Brenda Anderson, w/encl. LAW OFFICE OF ROBERT J. McDADE Not a Partnership - Employees of a Member Company of Zurich North America WALNUT HILL PLAZA 150 SOUTH WARNER ROAD, SUITE 270 KING OF PRUSSIA, PA 19406 (610) 687-8303 FAX (610) 225-8160 ROBERT J. MCDADE LISA BELLINO APELIAN MICHAEL W. CASEY WILLIAM E. DENGLER JOSEPH A. JULIANA April 19, 2005 Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 RE: Anderson v. Fry Communications, Inc., et all Cumberland County No. 04-3528 Our Client: Fry Communications, Inc. Date of Loss: 9/12/02 Dear Ms. Coyne: JEFFREY R. LIEBESMAN MATTHEW E. MCGUIRE JEFFREY W. MEEHAN MARK A. MINICOZZI KAREN SHORT NORRIS Kindly advise of the status of your client's response to the Request for Production of Document of Fry Communications. In addition, please provide copies of the photographs taken by Plaintiffs husband as well as the tax returns as referred to in the interrogatory answers. Thank you. Very truly yours, LAW OFFICE OF ROBERT J. McDADE BY: &/ BARBARA EY, Paralegal Email: barbwa-ganley®mrichna.com Direct Dial: (610)225-8175 BMG cc: Donald Dorer, Esquire Richard Jones, Fry Communications, Inc. Christine Sawyer, Zurich North America (Your File No.: 453-0068219-001) LAW OFFICE OF ROBERT J. McDADE Not a Parmership - Employees of a Member Company of Zurich North America WALNUT HILL PLAZA 150 SOUTH WARNER ROAD, SUITE 270 KING OF PRUSSIA, PA 19406 (610) 687-8303 FAX (610) 225-8160 ROBERT3.McDADE LISA BELLINO APELIAN MICHAEL W. CASEY WILLIAM E. DENGLER JOSEPH A. JULIANA May 12, 2005 Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 RE: Anderson v. Fry Communications, Inc., et al Cumberland County No. 04-3528 Our Client: Fry Communications, Inc. Date of Loss: 9112/02 Dear Ms. Coyne: JEFFREY R. LIEBESMAN MATTHEW E. McGUIRE JEFFREY W. MEEHAN MARK A. MINICOZZI KAREN SHORT NORRIS On October 25, 2004 you were served with a Request for Production of Documents for answer by your client. By letter dated December 9, 2004 you were reminded that the Request for Production of Documents was outstanding. On April 19, 2005 we again requested the status of your client's response to the Request for Production of Documents of Fry Communications as well as requesting copies of the photographs taken by Plaintiffs husband and the tax returns as referred to in the interrogatory answers. To date, we have not received any of the documents requested. Kindly provide your responses to said discovery requests within ten (10) days of the date of this letter in order to avoid the necessity of a Motion. Lisa Marie Coyne, Esqu Anderson v. Fry Communications, Inc., et al. May 12, 2005 Page 2 Thank you. Very truly yours, LAW OFFICE OF ROBERT J. McDADE BY :: 6 MATTHEW E. MCGUIRE ?- Email: matthew.mcguin a@zurichna.mm Dinct Dial: (610) 225-8167 MEM:bmg cc: Donald Dorer, Esquire Richard Jones, Fry Communications, Inc. Derek Hurlbert, Sr. Claims Specialist, Zurich North America (File No.: 453-0068219-001) Gt+ ts- G ?? tr: J,? A =T3? l ?„? ?(.. J:.. ? :?4 ? }'? i...J "O ' 1. T X Y S xu A -c u'? BRENDA M. ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JESSE D. EASH & FRY COMMUNICATIONS, INC., Defendant NO. 04-3528 CIVIL TERM ORDER OF COURT AND NOW, this 13"' day of June, 2005, upon consideration of the Motion of Fry Communications, Inc., To Compel Plaintiff's Response to Request for Production of Documents, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. /sa Marie Coyne, Esq. 3901 Market Street Camp Hill, PA 17011 Matthew E. McGuire, Esq. L,Vaw Office of Robert J. McDade 150 South Warner Road Suite 270 King of Prussia, PA 19406 Attorney for Defendant Fry Communications, Inc. Donald Dorer, Esq. 214 Senate Avenue Camp Hill, PA 17011 J> C6 :rc BY THE COURT, I At 1?i`r ?.1 v?rylry3HI ?V 3?J1?'Q 471tq MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. 1BERLAND COUNTY 1RT OF COMMON PLEAS 04-3528 TRIAL BY JURY OF 12 DEMANDED CERTIFICATE OF SERVICE I, Matthew E. McGuire, hereby certify that a true and correct copy of the June 13, 2005 Order of the Court setting for the a Rule Returnable within 20 days of service regarding the Motion to Compel Plaintiff s Response to Request for Production of Documents of Defendant, Fry Communications, Inc., has been served upon the following: Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011 Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 Via: first class mail on the 21st day of June, 2005. LAW OFFICE OF ROBERT J. McDADE UI&A L-' 4661 ? k>m'% Attorney for Defendant, Fry Communications, Inc. C? ?? ? { Cr c. ?S-n - __??n r L ? W . ?? ' ; , _?? " ' i W ?< ro c? COYNE & COYNE, P.C. By: Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney For Plaintiff BRENDA M. ANDERSON, : IN THE COURT OF COMMON PLEAS Plaintiff, : OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3528 CIVIL TERM Vs CIVIL ACTION - LAW JESSEE D. EASH and FRY COMMUNICATIONS, INC., Defendants JURY TRIAL DEMANDED PLAINTIFF'S OBJECTIONS TO SUBPOENAS PURSUANT TO RULE 4009.21 AND NOW COMES, the Plaintiff, Brenda M. Anderson, by and through her Attorneys, Coyne & Coyne, P.C. and aver the following in support of this objection to Noticed Subpoenas: On September 12, 2002 at approximately 9:15 o'clock a.m., Plaintiff Brenda Anderson was traveling west on Hogestown Road, in Silver Spring Township, Cumberland County, Pennsylvania, driving a 1998 GMC Jimmy and was stopped and stationary behind another vehicle that was stopped for a vehicle which was turning into the Main Difference Place. 2. At the same time, the Defendant lessee D. Eash was operating a Chevrolet 3500 pickup truck while using and speaking on a cellular telephone and driving directly behind Plaintiff traveling west on Hogestown Road, Silver Spring Township, Cumberland County, Pennsylvania. 3. Defendant failed to slow or stop his truck as he approached the stopped and standing line of traffic and Defendant's truck violently collided with the rear of Plaintiff's stopped vehicle. 4. As a result of the collision, Brenda Anderson was injured to include injury to her back which has resulted in no less than three back surgeries in less than three years since the collision. 5. On September 6, 2005, Defendant Fry Communications, hrc. served a notice of intent to serve subpoenas upon various medical providers. (See Attached Exhibits "A".) 6. The requested materials include documents from Plaintiff's date of birth to date, to present. 7. The requested forty-three years of medical and personal materials include material which is not relevant to these proceedings and Plaintiff is not seeking damages for aggravations of any pre-existing conditions or for residual conditions other than those related to the injuries sustained on September 12, 2002, the date of the collision. 8. The proposed subpoenas are overly broad and are not limited pursuant to the Pa. R.C.P. as they relate to discovery and Plaintiffs privacy rights. WHEREFORE, Plaintiff respectfully objects to the Subpoenas intended to be served upon Dr. Michael Peck, Harrisburg Hospital, Hanover Hospital, and Dr. Rychak. Dated: l9 St?v Respectfully submitted CO & CO .C. C By: ^1 Market Street Camp Hill, PA 17011 (717) 737-0464 Pa. S. Ct. No. 53788 Attorneys for Plaintiff 2 COMMONWEALTH O F PENN S YLV2N-N 2A COUNTY OF CUMBERLAND IN THE MATTER OF: - ----°-- COURT OF COMMON PLEAS ANDERSON SEP - 6 2005 TERM, v5- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER HOSPITAL PATHOLOGY HARRISBURG HOSPITAL MEDICAL RECORDS MICHAEL PECK, M_D. MEDICAL RECORDS JOHN S. RYCHAK, MD MEDICAL RECORDS TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MATTHEW E. MCGUIRE, 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. It 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: 08/31/2005 MCS on behalf of CC: MATTHEW E. MCGUIRE, ESQ_ - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-311438 S D S 5c-- C 0 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HANOVER HOSPITAL (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 Groun Inc 1601 Market Street Suite 800 Philadelph 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: MATTHEW E MCGUIRE, ESQ. ADDRESS: 150 S WARNER ROAD SUITE 270 KING OF PRUSSIA. PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SEP 2 0 _'CDs BY THE COURT: Prothonotary/ d erk, Cit Di 'sion Date: A/ Deputy All, Seal of the Court 59564-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HANOVER HOSPITAL DEPARTMENT OF PATHOLOGY 300 HIGHLAND AVENUE HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all pathology reports and records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-581414 5 9.5 G 4- L 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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.lnc 1601 Market Street, Suit 900 Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the cettificate 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: MATTHEW E. MCGUIRE. ESO ADDRESS: 150 S. WARNER ROAD SUITE 7 KING OF PRUSSIA. PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil D tst in ?O? Deputy Date: Seal of the Court 59564-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT ST. HARRISBURG, PA 171012099 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please can for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-580980 S 9 5 6 4- L 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON File No. CUMBERLAND 04-3528 vs. FRY COMMUNICATIONS, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MICHAEL PECK M.D. (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 MC'S Grouro Inc.. 1601 Market Street. Suite 800 Philad phia 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: MATTHEW E. MCGUIRE. ESO ADDRESS: 150 S WARNER ROAD SUITE 270 KING OF PRUSSIA PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: 7 Prothonotary/ erk,/Civil ' is onj c-? Deputy Date: Seal of die Court 59564-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR MICHAEL PECK, M.D. 3130 GRANVIEW ROAD BLDG. A HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-580982 5 9 5 6 4- LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ JOHNS RYCHAK MD (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 MCC 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: MATTHEW E MCGUIRE. ESQ. ADDRESS: 150 S. WARNER ROAD SUITE 270 KING OF PRUSSIA PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Deputy Date: T? QS? Seal of the Court Prothonotary/Clerk, Civil- tsio 59564-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN S. RYCHAK, MD 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-580984 5 9 S 6 4-L,0 4 CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, hereby certify that true copies of the Plaintiffs' Objections to Subpoenas Pursuant to Rule 4009.22 have been served upon the below-referenced individual by sending the same by first class mail, postage prepaid, addressed as follows: The MCS Group, Inc. Harrisburg Hospital 1601 Market Street, Suite 800. ATTN: Medical Records Correspondence Philadelphia, PA 19103 111 South Front Street Harrisburg, PA 17101 Matthew E. McGuire, Esquire 150 S. Warner Road, Suite 270 King of Prussia, PA 19406 Dr. Michael Peck 2882 West Kings Street Abbottsotwn, PA 17301 Hanover Hospital ATTN: Medical Records Correspondence 300 Highland Avenue Hanover, PA 17331 Donald R. Dorer, Esq. 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Dated: I,?- $t2? - 0.- Dr. John Rychak 99 November Drive Camp Hill, PA 17011 ??,tN- A-0 rie Coyne, Esquir q C & COYNE, P.C 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 O i J =7 n w? o "ma - c MATTHEW E. McGUIRE, ESQUIRE Attorney I.D. No: 86822 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANTS FRY COMMUNICATIONS, INC. 1BERLAND COUNTY JRT OF COMMON PLEAS 04-3528 TRIAL BY JURY OF 12 DEMANDED MOTION TO STRIKE PLAINTIFFS' OBJECTIONS TO SERVICE OF SUBPOENAS Defendant, Fry Communications, Inc., by their attorney, Matthew E. McGuire, Esquire, move this Honorable Court to enter an Order striking Plaintiff's objections to subpoenas and in support thereof avers the following: This is an action brought by Plaintiff for personal injuries allegedly sustained by Plaintiff Brenda M. Anderson in a motor vehicle accident on September 12, 2002, through the alleged negligence of the Defendants. 2. In Plaintiff's Complaint she alleges that she sustained serious injuries to her muscles, nerves, tendons, connective tissues, skin, bones and organs of her body, including but not limited to severe strain to the cervical and lumbar vertebrae and contiguous soft tissue, back pain and nerve shock. A true and correct copy of Plaintiffs Complaint is attached hereto as Exhibit "A". 3. On September 8, 2005, plaintiff was deposed. She testified that the accident occurred on September 12, 2002. She first sought treatment in December of 2002. She was diagnosed with a large, severe disc herniation and had two subsequent back surgeries including a laminectomy. She claims that she never had any back problems before this accident. 4. During the course of discovery, Defendants sought to obtain records from Hanover Hospital, Harrisburg Hospital, Michael Peck, M.D. and John S. Rychak, M.D. through The MCS Group, Inc., and on August 31, 2005, a Notice of Intent was forwarded to counsel for Plaintiff. True and correct copies of the Notice of Intent and accompanying subpoenas are attached hereto as Exhibit "B". 5. On September 19, 2205, counsel for plaintiff filed objections to the subpoenas addressed to Hanover Hospital, Harrisburg Hospital, Michael Peck, M.D. and John S. Rychak, M.D. on the grounds that the subpoenas were overly broad and not relevant to the issues in this case. True and correct copies of Plaintiffs objections are attached hereto as Exhibit "C". 6. Defendant, Fry Communications, Inc., will be unduly prejudiced in preparing their defense of this matter and evaluating Plaintiff s significant damage claims without her medical records from Hanover Hospital, Harrisburg Hospital, Michael Peck, M.D. and John S. Rychak, M.D. WHEREFORE, Defendant, Fry Communications, Inc., requests your Honorable Court to enter an Order striking Plaintiff s objections to service of subpoenas. Respectfully submitted, LAW OFEICE OF ROE MATTHEW E. McGUII Attorney for Defendants, Fry Communications, Inc.. VERIFICATION Matthew E. McGuire, Esquire, hereby states that he is the attorney of record for Defendant(s), Fry Communications, Inc., in this action and veri fies that statements made in the foregoing Motion to Strike are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. LAW OFFICE OF ROBERT J. McD Date: d (? p? MATTHEW-F.1GIc Attorney for Defendant, Fry Communications, Inc. MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON CUMBERLAND COUNTY V. COURT OF COMMON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS, INC. TRIAL BY JURY OF 12 DEMANDED MEMORANDUM OF LAW IN SUPPORT OF MOTION TO STRIKE OBJECTIONS TO SUBPOENAS PURSUANT TO 4009.21 This is an action brought by Plaintiff, Brenda M. Anderson, for personal injuries allegedly sustained in a motor vehicle accident on September 1:2, 2002, through the alleged negligence of the Defendant, Fry Communications, Inc.. Defendant, Fry Communications, Inc. has requested the Plaintiff's medical records and the Plaintiff has objected to these requests on the grounds that the subpoenas are broad based and requesting iinformation that is privileged and not relevant to the issues in this case. In Plaintiff's Complaint she alleges that she suffered serious injuries to her muscles, nerves, tendons, connective tissues, skin, bones and organs of her body, including but not limited to severe strain to the cervical and lumbar vertebrae and contiguous soft tissue, back pain and nerve shock. By making a claim for personal injuries a plaintiff must expect reasonable inquiry and investigation into the claim and to that extent privacy interests are circumscribed. Forster v. Manchester, 189 A.2d 147,150 (Pa. 1963). The present action involves a claim for personal injuries, and the records that have been subpoenaed are medical records, which are undoubtedly relevant. WHEREFORE, Defendant, Fry Communications, Inc., requests your Honorable Court to enter an Order striking Plaintiff's objections to Service of Subpoenas. Date: 4t6(v B?( LAW OFFICE OF ROBERT J. Attorney for Defendant, Fry Communications, Inc. MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON CUMBERLAND COUNTY V. COURT OF C014MON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS, INC. TRIAL BY JURY OF 12 DEMANDED ATTORNEY CERTIFICATION OF GOOD FAITH The undersigned counsel for Defendant, Fry Communications, Inc., hereby certifies and attests that he has made a good faith effort regarding the discovery matter contained in the foregoing discovery motion in an effort to resolve the specific discovery disputes at issue, and further, that despite all counsels' good faith attempts to resolve the disputes, they have been unable to do so without Court intervention. LAW OFFICE OF ROBERT J. Mc E Date: t0 a6, MNI ITIEW E. Mc Attorney for Defendant, Fry Communications, Inc. 88/13/84 15:48:15 Cf, H-CH3-> 8218488842267189488 RightF M NDA3LANDMWN, 111whw TL .xsu D. ms e3 Detendamt IN THB COURT OF COT4X014 P"AS OF CUNXS I,Aivlo000hVY,$ENNSYLVANU :vo. o?- :s7.s cavn.'1'?tl+I aM ACTION -LAVP : JWT Thu Dmmaded Yam have btec sued in cam Tryon wisp to defcd apwt the Olanas set Smth in the WJowmg MRS, YOU must Ub acdw within rmeotY (20) dsya after this cftVlaimt sad no*e are served, by entering a written sppearmoe pemnslly or by Atb=ey and fling is wrmu with the court our ddlmass or obletsirms to the vle?ns art firth apka you. You tme warned @ut tf you fail to do so the case Wary proceed vAdm A you aid a judp=t rosy ba ontared against you by dc come wiryour firdw notieo rot aoy ttiotteY aLlimed in the eamplaiat rx fqs aey adsa shdta. ormllef rtyttcstrd 1:Y 11m Plaimtiri You msy [we money or property or other d- tE itrQ nt tO you. YOU SHOULD TARE TMS 8AP$t TO YOM I.AWWR AT ONCE. IF YOU DO NOT GAVE A LAVrM OR CA14M AFFORD ONE, GO TO M 7'F3gP oM TEE OffB: i SET FORTH BELOW TO FIND 007 WFIERI: YOU CAN GErLEGAL HELP. Cltmburbxd COMY 8v AsmclAon 32 SOT& uad%rd su%d C&Trm* PA 17813 (Y17)249-3146 ?r ^iJ6. page ?B 1- TRUE GOPY FROM aEC ORD tr; ! ma so yt Bald =a D isle, h. Rd>ti a'Jey Ilk ?•- boa ahonapiry RECEIVE) NNIAJC, h, 7;35AM M/13/94 15:49:81 a H_CH3-> B21BM00422671EI9400 RightF Page 889 AJG. 9. 2034 :I : AAK LL" l mt Do-u t;r Mp an nu DEPT e '41). 3' 19 P. 9,'21 M. L7C2 D009 MMDA M. A N, : DF r= COMff OF COMMON ffAAS 07 No. 0 3 . cavil. De[eadant : CRMAMON-LAW 1ry'kd DemomWed TO 1M RONOAADLF, 7C7Dt3>3S OF SAID COURT- AND NOW COM me PlamtiQ 1 nm& M Andtamm, by and 9aoamgh ha attorta n =NE & COYNL, P.C., and avers the fOHowiM m mppott of this co VWm I. F1°'nft Areada M, Andaacm, is ay adult iodMdual nptidiop at 475 Sample. gridp Rn 4 EDOIa, Curaw ud County, Pamaaeglgwr L 2. pmt 70" Ez* is m adult individual raiding at 288 -%=Wbml gmd, -N3oAmaicabamg, Cumberland County, paomaylv®ia, 8*='? t; 2062 at .. ..iPFaa:dt4at?>h913dalpelt M on Iioacutown Road, in Silva S*jug Townvltip, •Ci?Iferlaad.Cougty'-y'.:? ?^i?r'?fa,c :t= ' ,i, . YlYaoia;-diytng.a? :.?ti:•. }'•`" m'uny lad will stopped and itatiom y behind mother va3iole tbu roeas stopped spl a veivele+ahich w" making a turn into the Maiu bommeext Place. 4, At 110 aamae limey the Defe'&W was Dpatat' g a Uw'mlat 3SDD pickup truck wInjo usiep and TmIdag DD a cellular Ul phom and dttvla8 &mdy bebmd P'haat & raveling wet on Hogeuawn Ctaad, Sliver Spft Townabip, QW*erlard Coumy, pannaylvama, 3ECEIl'?D PIkfEAJF, E. 7: 35).2 M/13/04 15:49:2B Ct H CB3-> 0218490042267189400 RigirtF AM. 9. 2034 A: :9.SK Page 010 'x].3:19 P?W'.71 wale ••1,.: 5. Defendant &= Sailed to alow or atop his truck as he approached the woMed and stawfta lime of traffic and DaSmdmCs tuck violtdly eoAided with dm am a ftntff I stepped 'a?tdtle. 6. As a tower of the marsmd mldaioo, l'laiaeiff was mtown.ioleatly agmnat Bu interior of the vohiclc ad sastaised aedoms f11*91 to her mtmles, ttervesr tendons, ooambordn slashes, skin, bmw and organs of 3er body: including but not Ihtdted to cevem strain to the ter" and h r1w vertebras and cmntipwas ao$ tiasee, back pm egd nea:ve shock. 7. As a result of the 009iAaa, plaiutifl'suffered wvm injuries to her body as the pature Of pa» im her back jwius to tics sbdonaeo and bank, stiffness in her ramk. back and baps, pain dawn her legs; and [ awd amS=h- 8. Ae a direct and ProxiAane resort aa'the collfaiam and TJefeodant'a aegli ,scant cendgsL Plttioti$ has suffered, crud w41 saffw in the 4btm4pmati egany,, arweV and maamvemieue. 9. Addititma*, Im 11 laiirdfE Au rendered sick, scar, and &scaacued, and was made m cndecga mean! mpfth tatd phyalcal pauaa liom which she rtrpfeteti; cull suff0a and wt71 ooct mue ps '" dY he aforetsid htta ins PWatiff hen vTaAed muivu.mmia elF Fca' Y frtb tFdacal Care r>td eug W opafim, and theaapy and else wlll be regttared to arpmd sdditionhl WWI of money farthe atm PjXBOW k,[he atv. 11. As a rem& of Dehndeaat's negligent tmn&w% 01411W was unable to fe0y anaM is and a4cy the acdwe and pbyricA aadvitias as she had eofoyed and utgaged fin prior to coRidgti caused by ' Deiandant'a negt once and anlt ooetian So in the fntaa,_ 12. As a rosmc of Defendant's neyfigeaee, PfuisAff wan wous so work for an rode wft period of time. U. AsitM%I[tettheoeilimam,ATaiaaf[n•Miwage agent to hut velkle. 6E KIVED 4191670. 6. 1,35At - 08/13/84 15:495H 9. 2UJ4 .1 2U. Pngc 811 C(i H-CH3-7 HZ104HH84ZZ6710948B RightFr t).3:1y • ZA tu+?M }?tiaf [3t6UF'QRiM5 11hPT i 91719?1R95fi0 N - ru. txe 9011 14. At the time of The aceident, Se ee T«++7 of SaDeteMw consi" of the fuHwridg (a) faitiagto hasp his vehicle underpsopor andadequats mftl; (b) figidg to lptep a cnct(1l sad dtlbs=t watch an tba road; (e) ope , U g and taring a ae11u1ffi teieplmr wbile operatiog; and dtMng a gmtor wNcle oa a tmay pmthe roadway, (d) opeeatftbm vcbWc mo fast for cmmhd=j (e) failing 10MV a FLoperdl WOOb"d tba piuad Ws vg *le; 0 failveg to slaw cc to bring bislhe velriok to a amp so aR t0 avoid flte impact with the teat of pb*d ifra gWWM veNcle: 00 fdit to 80*W wA the provisim of Section 3310 of the Permlvama Motes lreblcle Cede relating to the operation of motor vehicles, spedfa:a[ag as obey relate m the atateeaid sue ofmllipme: and (h) arch other aep or omiMom as may be semled in the comae of dimovhy, or at the trial of?scasc, WRERMFO II -- -? •'- wd mspmtfulty nWizu that Su Watt bpd sa ha &' or sad agmial J??f dmC ` 1m yatt biwtrs of The mmdan ry acbivadcm amouza for aria oct>tny yhm L,ktart tmd ooiirtCOal9i 8sypeodbRy auhmoritrcd: Damd:_2? 4?~ HUM"D T',h4ddUi. CORNS & COYNE, P.a Pa. Ssgsyme Ct. No. 5388 (117)737-M& ' Marie -- 3901 Mss7xt 9t. Camp HE. PR 171111 AttarnrytfarPi?NfFJJ' I' For 812 g;ghi.Fr cm ? CB3-y ?1m880+422b7109 15" '? 9}.3..19 P•?,?. D9i2 , 58:26 [iN cs WT a a{°?'YL??+ I 1 1 r m$???Cpq?C21A 9f4b?? f9 nyeypsSet2onb ????,y]ectm3uP? bs ' yµlat9Y+ C8A5a4tK• n fi I n .. 1 .. COMMONWEALTH O F- P ENN S YLVAN =A COTJI1TTY OF CTTMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON -VS- FRY COMMUNICATIONS, INC. NOTICE OF INTENT TO SERVE A SUBPOENA TO THINGS FOR DISCOVERY PURSUANT T HANOVER HOSPITAL PATHOLOGY HARRISBURG HOSPITAL MEDICAL RECORDS MICHAEL PECK, M.D_ MEDICAL RECORDS JOHN S. RYCHAK, MD MEDICAL RECORDS TERM, CASE NO: 04-3528 TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MATTHEW E. MCGUIRE, 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 NICS or by contacting our local MCS office. DATE: 08/31/2005 MCS on behalf of MATTHEW E. MCGUIRE, ESQ. Attorney for DEFENDANT CC: MATTHEW E. MCGUIRE, ESQ_ - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact THE MCS GROUP INC. .1601 MARKET STREET #800 PHILADELPHIA, PA. 19103 (215) 246-0900 DE02-311438 5 9 5 6 4= C 0.3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF.CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HANOVER HOSPITAL (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 Cnouu Inc 1601 Market Street. Suite 500. 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 FOLLORTING PERSON: NAME: MATTHEW E. MCGUIRE, ESQ. ADDRESS: 150 S. WARNER ROAD SUITE 270 KING OF PRUSSIA. PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/ erk, C' i Di 'sion SEP Z 0 2003 Date: Deputy Seal of the Court 59564-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HANOVER HOSPITAL DEPARTMENT OF PATHOLOGY 300 HIGHLAND AVENUE HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all pathology reports and records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject:, BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-581414 5 9S G4 -L O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND vs. ANDERSON FRY COMMUNICATIONS, INC. File No. _ CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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 Str t 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 ceftificate 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: MATTHEW E. MCGUIRE. ESO ADDRESS: 150 S WARNER ROAD SUITE 270 KING OF PRUSSIA. PA 1 406 TELEPHONE:. (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant FP 2 0 2975 Date: Seal of the Court BY THE COURT: Prothonotary/CI k, Civil 'vts, n Deputy 59564-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT ST. HARRISBURG, PA 171012099 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic; form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 S1310-580980 S 9 5 G 4- 1,0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. CUMBERLAND 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MICHAEL PECK M.D. (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 MC'S Group. Inc 1601 Market Street Suite 800 Philadelphia PA 12103 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: MATTHEW E. MCGUIRE. ESQ. ADDRESS: 150 S. WARNER ROAD SUITE 270 KING OF PRUSSIA. PA 19406 TELEPHONE: 215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothono ary/Q erk, Civil 1 on q Up?nmG U u Lu_ Date: ? 14 16?)S Deputy Seal of the Court 59564-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR MICHAEL PECK, M.D. 3130 GRANVIEW ROAD BLDG. A HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports; medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SU10-580982 5 9 S 6 4- L 0 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON File No. _ CUMBERLAND 04-3528 VS. FRY COMMUNICATIONS, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHNS RY AK MD (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 MC'S Groun Inc 1601 Market tr et S 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: MATTHEW E. MCGUIRE. ESQ. ADDRESS: 15Q S. WARNER RQAD SUITE 270 KING OF PRU44MA PA 19406 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil isto CEP Z D 2019 Date: zdDeputy o?.? Qb? Seal of the Court 59564-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN S. RYCHAK, MD 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 SIJ10-580984 5 9 S 5 4 -T., 04 COYNE & COYNE, P.C. By: Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 BRENDA M. ANDERSON, Plaintiff, Vs JESSEE D. EASH and FRY COMMUNICATIONS, INC., Defendants Attorney For Plaintff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3528 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S OBJECTIONS TO SUBPOENAS PURSUANT TO RULE 4009.21 AND NOW COMES, the Plaintiff, Brenda M. Anderson, by and through her Attorneys, Coyne & Coyne, P.C. and aver the following in support of this objection to Noticed Subpoenas: 1. On September 12, 2002 at approximately 9:15 o'clock a.m., Plaintiff Brenda Anderson was traveling west on Hogestown Road, in Silver Spring Township, Cumberland County, Pennsylvania, driving a 1998 GMC Jimmy and was stopped and stationary behind another vehicle that was stopped for a vehicle which was turning into the Main Difference Place. 2. At the same time, the Defendant Jessee D. Eash was operating a Chevrolet 3500 pickup truck while using and speaking on a cellular telephone and driving directly behind Plaintiff traveling west on Hogestown Road, Silver Spring Township, Cumberland County, Pennsylvania. 3. Defendant failed to slow or stop his truck as he approached the stopped and standing line of traffic and Defendant's truck violently collided with the rear of Plaintiff's stopped vehicle. 4. As a result of the collision, Brenda Anderson was injured to include injury to her back which has resulted in no less than three back surgeries in less than three years since the collision. 5. On September 6, 2005, Defendant Fry Communications, Inc. served a notice of intent to serve subpoenas upon various medical providers. (See Attached Exhibits "A".) 6. The requested materials include documents from Plaintiff's date of birth to date, to present. 7. The requested forty-three years of medical and personal materials include material which is not relevant to these proceedings and Plaintiff is not seeking damages for aggravations of any pre-existing conditions or for residual conditions other than those related to the injuries sustained on September 12, 2002, the date of the collision. 8. The proposed subpoenas are overly broad and are not limited pursuant to the Pa. R.C.P. as they relate to discovery and Plaintiffs privacy rights. VVHEREFORE, Plaintiff respectfully objects to the Subpoenas intended to be served upon Dr. Michael Peck, Harrisburg Hospital, Hanover Hospital, and Dr. Rychak. Dated: I R Sera PI Respectfully submitted COYI & CO .C. By. L ?001 Market Street Camp Hill, PA 17011-4217 (717) 737-0464 Pa. S. Ct. No. 53788 Attorneys for Plaintiff 2 CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, hereby certify that true copies of the Plaintiffs' Objections to Subpoenas Pursuant to Rule 4009.22 have been served upon the below-referenced individual by sending the same by first class mail, postage prepaid, addressed as follows: The MCS Group, Inc. 1601 Market Street, Suite 800. Philadelphia, PA 19103 Harrisburg Hospital ATTN: Medical Records Correspondence 111 South Front Street Matthew E. McGuire, Esquire 150 S. Wainer Road, Suite 270 King of Prussia, PA 19406 Hanover Hospital ATTN: Medical Records Correspondence 300 Highland Avenue Hanover, PA 17331 Donald R. Dorer, Esq. 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Dated: /9'- $r0? 0.- Harrisburg, PA 17101 Dr. Michael Peck 2882 West Kings Street Abbottsotwn, PA 17301 Dr. John Rychak 99 November Drive Camp Hill, PA 17011 r A-0- qsa ?Oie Coyne, Esquir COYNE & COYNE, P.C 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON CUMBERLAND COUNTY V. COURT OF COMMON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS, INC. TRIAL BY JURY OF 12 DEMANDED CERTIFICATE OF SERVICE I, MATTHEW E. McGUIRE, ESQUIRE, hereby certify that a true and correct copy of the foregoing Motion to Strike Objections to Service of Subpoenas was mailed via first class mail, postage prepaid to the following counsel of record: COUNSEL FOR PLAINTIFF: Lisa Marie Coyne, Esquire Coyne & Coyne,P.C. 3901 Market Street Camp Hill, PA 17011 717-737-0464 COUNSEL FOR CO-DEFENDANT JESSE D. EASH: Donald Dorer, Esquire 214 Senate Avenue Camp Hill, PA 17011 717-731-0988 LAW OFFICE OF ROBERT J. McDADE Date: MAI I HEW E. c McGUIRE, ESQUIRE Attorney for Defendant, Fry Communications, Inc. r1 - 0 ~? LJ r Ito .s ?i C7 --1 S rr; C N ;. S BRENDA M. ANDERSON IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JESSE D. EASH & FRY COMMUNICATIONS, INC., Defendant NO. 04-3528 CIVIL TERM ORDER OF COURT AND NOW, this 17`h day of October, 2005, upon consideration of Defendant's Motion To Strike Plaintiffs' Objections to Service of Subpoenas, a discovery conference is scheduled in chambers of the undersigned judge for Thursday, December 15, 2005, at 3:30 p.m. BY THE COURT, isa Marie Coyne, Esq. 3901 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Ronald Dorer, Esq. 214 Senate Avenue Camp Hill, PA 17011 Attorney for Defendant Jesse D. Eash ,,?Matthew E. McGuire, Esq. 150 South Warner Road Suite 270 King of Prussia, PA 19406 Attorney for Defendant Fry Communications, Inc. J :rc ,J nbL' ' ? i 3.'L ?U BRENDA M. ANDERSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 04-3528 CIVIL TERM JESSE D. EASH and : CIVIL ACTION LAW FRY COMMUNICATIONS, INC.,: Defendant : ORDER OF COURT AND NOW, this 15th day of December, 2005, upon consideration of the motion of Defendant Fry Communications, Inc., to strike Plaintiff's objections to service of subpoenas and following a conference in chambers of the undersigned judge in which Plaintiff was represented by Lisa Marie Coyne, Esquire, Defendant Fry Communications, Inc., was represented by Matthew E. McGuire, Esquire, and Defendant Jesse D. Eash was not represented by counsel (the Court having excused Donald R. Dorer, Esquire, from participation in the conference) it is ordered and directed as follows: 1. Defendant's motion to strike plaintiff's objections to service of subpoenas is denied; provided, that Plaintiff shall be required to respond to the subpoenas to the extent of providing (a) all of Plaintiff's medical records of the medical providers referred to in the subpoenas for a period commencing 5 years prior to the motor vehicle accident involved in this case on September 12, 2002, and (b) Plaintiff's medical records of said providers ;i I S .S WV OZ 0-10 sou Aii'Ji t`- s' c;d ?:jHi 20 _ C Lally! related specifically to back pain or treatment for a back injury, regardless of the time period. 2. No other relief is granted at this time. By the Court, J., es 'fey 01er, -'J ,Lisa Marie Coyne, Esquire COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 For Plaintiff Xonald R. Dorer, Esquire 214 Senate Avenue Suite 503 J Camp Hill, PA 17011 For Defendant Jesse D. Eash Matthew E. McGuire, Esquire 150 South Warner Road Suite 270 King of Prussia, PA 19406 For Defendant Fry Communications, Inc. mlc l?h N MICHAEL A. DeTOMMASO, ESQUIRE Attorney I.D. No: 72248 LAW OFFICE OF JOHN P. HENDRZAK 3773 Corporate Center Parkway, Suite 180 Center Valley, PA 18034 (610) 709-8705 V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANT, FRY COMMUNICATIONS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 04-3528 TRIAL BY JURY OF 12 DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above captioned matter on behalf of Defendant, Fry Communications, Inc. Respectfully Submitted, LAW OFFICE OF JOHN P. HENDRZAK MICHAEL A. DETOMMASO, ESQUIRE Attorney for Defendant, Fry Communications, Inc. Cz) CL) MATTHEW E. McGUIRE, ESQUIRE ATTORNEY FOR DEFENDANTS Attorney I.D. No: 86822 FRY COMMUNICATIONS, INC. LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 BRENDA M. ANDERSON CUMBERLAND COUNTY V. COURT OF COMMON PLEAS JESSE D. EASH & NO. 04-3528 FRY COMMUNICATIONS, INC. TRIAL BY JURY OF 12 DEMANDED WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance in the above captioned matter on behalf of Defendant, Fry Communications, Inc. LAW OFFICE OF ROBERT J. McDADE MATTHEW E. McGUIRE, ESQUIRE Attorney for Defendant, Fry Communications, Inc. r? ; C>t t?> ?::- _ ? ? _, N 'S4 `. " -'Gi ' ?.? "i f.. ; ? b ?_ •'- BRENDA M. ANDERSON, Plaintiff, Vs JESSEE D. EASH and FRY COMMUNICATIONS, INC., Defendants TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3528 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE Please withdrawal the appearance of Coyne & Coyne, P.C. of behalf of the Plaintiff in the above matter. COYN" COYNE, P.C. 3 By sy/o 6 a Marie Coyne, SQUIRE 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Enter the appearance of NAVITSKY, OLSON & WISNESKI on behalf of the Plaintiff in the above matter. NAVIT , OLS & WIS SKI By: David . Wisneski 2040 Linglestown Road, Ste. 303 Harrisburg, PA 17110 (717) 541-9205 Pa. S. Ct. No. S Attorney for Plaintiff rv -Tj .. r it 7 yam, 7 - i's3 A r?? C s? ??y di CERTIFICATE OF SERVICE I, Lois E. Stauffer, an employee of the law firm of Navitsky, Olson & Wisneski LLP hereby certify that a true and correct copy of the foregoing Praecipe for Withdrawal/Entry of Appearance was served upon the following persons by first-class United States mail, postage prepaid on May 18, 2006 as follows: Donald Dorer, Esquire Snyder & Dorer 214 Senate Avenue Suite 503 Camp Hill, PA 17011 Counsel for Defendant Jessee D. Eash Michael A. DeTommaso, Esquire Law Office of John P. Hendrzak 3773 Corporate Center Parkway Suite 180 Center Valley, PA 18034 Counsel for Defendant Fry Communications, Inc. C J??J? ?J Lois E. Stauffer CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. MUNN COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 1 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 06/13/2006 u'l beh f of MI HAEL A. DETOMMASO, ESQ. A DEFENDANT ttorney for R1.09S 133-H DE11-0631255 59564-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL RECORDS X-RAY ONLY BILLING ONLY MEDICAL, BILLING, MEDICAL RECORDS X-RAY ONLY BILLING ONLY COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 AND X-RAY(S) TO: DONALD R. DORER, ESQ. LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL A. DETOMMASO, 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: 05/24/2006 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.09S 133-H DE0220S13038-59(564-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HANOVER GENERAL HOSPITAL (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 C= W. Inc._ 1601 Market Suit 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: MICHAEL A. DETOMMASO. ES ADDRESS: 3773CORPORATECTR_ PKWY TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 1 3 2006 BY COURT: Pro ono ar' c, ivil ivision Date: v Deputy Seal of the Court 59564-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HANOVER GENERAL HOSPITAL 300 HIGHLAND AVENUE HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 R1.09S 133-H SU10-0623792 59564-LO5 CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -vS- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 06/13/2006 o ha MICHAEL A. DETO[M9ASO, ESQ. Attorney for DEFENDANT R1.09S 133-H DE11-0631256 59564-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL RECORDS X-RAY ONLY BILLING ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS X-RAY ONLY BILLING ONLY TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 05/24/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact R1.09S 133-H MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 DE0220S$3048-69(564 -C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON File No. 04-3528 VS. FRY COMMUNICATIONS, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HANOVER GENERAL. HOSPITAL (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 1123 C== Inc.- 1601 MUk&t,;tlreet- Suite 800 Philad lphia 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: MICHAEL A. DETOMMASO E ADDRESS: 3773CORPORATFCTR PkW TELEPHONE: _(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE C T: Prothono /Clerk i sion JUN 1 3 2006 Date: 19 62(?( Deputy Seal of the Court 59564-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HANOVER GENERAL HOSPITAL 300 HIGHLAND AVENUE HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING ANY AND ALL MRI'S. PLEASE PROVIDE A FILMS INVENTORY. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 R1.09S 133-H SU10-0623794 59564-LO6 CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND _VS_ FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 06/13/2006 M on b f i MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT R1.09S 133-H DE11-0631257 59564-L07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -vs- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL RECORDS X-RAY ONLY BILLING ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS X-RAY ONLY BILLING ONLY TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 05/24/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact R1.09S 133-H MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 DE0222513058-cs9(564 -C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ILANOVER GENERAL HOSPTT 1 (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: **** SFF ATTACHED RIDER **** at The M C rgo Inc 1601 Market Street Suite 800 Philadelpbi 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: MICHAEL A DETOMMASO ESO ADDRESS: 3773 CORPORATE. CTR. PKWY SUITE 180 CENTER VALLEY. PA 8034 TELEPHONE: Spa 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ?j 3UN 1 3 2006 / Date: Ic? ? )b r -f Seal of the Court BY THE C 1?ItT: Prothono /Cler i sion Deputy 59564-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HANOVER GENERAL HOSPITAL 300 HIGHLAND AVENUE HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 R1.09S 133-H SU10-0623796 59564-LO7 CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND _VS_ FRY COMMUNICATIONS. INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 06/13/2006 M ?onb if i MICHAEL A. DETOMMASO, ESQ. ? Attorney for DEFENDANT R1.09S 133-H DE11-0631258 59564-L08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL RECORDS X-RAY ONLY BILLING ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS X-RAY ONLY BILLING ONLY TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, E9Q. MCS on behalf of MICHAEL A. DETOMMASO, 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: 05/24/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact R1.09S 133-H MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 DE02215$304 B-499664-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 TO: Custodian of Records for MAGNETIC IMAGING CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER**** at The M CS roan. 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: MICHAEL A. DETOMMASO, ES ADDRESS: 3773 CORPORATE CTR PKWY TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 1 3 2006 Date: v 4 G1/? Seal of the Court BY THE CO T: Prothono y/Clerk, i" on Deputy 59564-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17050 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 R1.09S 133-H SU10-0623798 59564-LO8 IN THE MATTER OF: ANDERSON FRY CERTIFICATE ®' "/GUL PREREQUISITE TO SERVICE OF A SUBPOENA /?I7 PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 06/13/2006 on al MICHAEL A. DETOAttorney for DEFENDANT R1.09S 133-H DE11-0631259 59564-L09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -vs- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL RECORDS X-RAY ONLY BILLING ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS X-RAY ONLY BILLING ONLY TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS On behalf of MICHAEL A. DETOMMASO, 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: 05/24/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact R1.09S 133-H MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 DE022MS$393 6-595 64-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 TO: Custodian of Records for HARRISBURG HOSPITAL (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 Crnnn Inc 1601 Market Street- Suite 900, v1,:14Aelgb:a pa 10103 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: MICHAEL A. DETOMMAS ADDRESS: 1773 ORPO ATE CTR. P TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 1 3 2006 BY THE URT: Protho otary/Cler t i sion Deputy Date: ? Q f o?15 Seal of the Court 59564-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 R1.09S 133-H SU10-0623800 59564-L09 CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND _VS_ FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 06/13/2006 ? M?/ ICHAELbA. DETO???? Attorney for DEFENDANT R1.09S 133-H DE11-0631260 59564-L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL RECORDS X-RAY ONLY BILLING ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS X-RAY ONLY BILLING ONLY TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 05/24/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact R1.09S 133-H MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 DE02208$3088-cFs9(564-CO3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON File No. 04-3528 VS. FRY COMMUNICATIONS, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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 Crmun. Inc._ 1601 Market qtreet 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: MICHAEL A. DETO A.O. ESO. ADDRESS: 3773 CORPORATE CTR. PKWY QUITE 180 CENTER VALLEY- PA 18034 TELEPHONE: (215) SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE C URT: Prothor} tary/?1 rvil 'sion JUN 1 3 2006 Date: J_?9 ?Ob(., Deputy v Seal of the Court 59564-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HARRISBURG HOSPITAL RADIOLOGY DEPT. 17 S. MARKET SQ. HARRISBURG, PA 17105 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. PLEASE PROVIDE A FILMS INVENTORY. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 R1.09S 133-H SU10-0623802 59564-L10 CERTIFICATE IN THE MATTER OF: ANDERSON FRY PREREQUISITE TO SERVICE OF A SUBPOENA ORIGINAL PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 06/13/2006 be o / /MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT R1.09S 133-H DEI-1-0631261 59564-Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL HANOVER GENERAL HOSPITAL MAGNETIC IMAGING CENTER HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL RECORDS X-RAY ONLY BILLING ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS X-RAY ONLY BILLING ONLY TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS On behalf of MICHAEL A. DETOMNASO, 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: 05/24/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact R1.09S 133-H MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 DE022M3$3046-59(564-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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 Groim. Inc.. 1601 Market Street, Suit 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: MICHAEL A. DETOMMASO. ES ADDRESS: 3773 CORPORATE CTR_ PxWV TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 1 3 2006 Date: ? Seal of the Court BY THE 7 44 T: . PProthondGLry /Cler 1 Di lion Deputy 59564-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HARRISBURG HOSPITAL BILLING RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Date of Birth: 09-22-1962 R1.09S 133-H SU10-0623804 59564-L11 r_a t ' =' ? O -i1 <T ? (..- T. -n ,,.,_ __..r. U1 t?; G? TVn =, _`;? ) _ ?.? ? ?1' ` , ?^? CN N& 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA ` PURSUANT TO RULE 4009.22ORI F 1 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -vs- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 v MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 S on beha f of ???(? ?? • (?tUJI'_J IIIETO OSQ. for DEFENDANT R1.15S 133-H DE11-0649215 59564-L12 i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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 J TO: DONALD R. DORER, ESQ. LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ES Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.15S 133-H DE02-0341483 59564-C03 >>> LOCATION LIST <<< PAGE: 1 I LOCATION NAME RECORDS REQUESTED ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE MEDICAL, BILLING, INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) R1.15S 133-H DE02-0341483 59564-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHO SURGEONS OF CENTRAL PA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** 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: MICHAEL A. DETOMMASO, ES ADDRESS: 3773 CORPORATE-CTR,_ PKWY CENTER VALLEY. PA 18034 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE CO T: Prothon tart'/Cler ivi In Olt a Deputy Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHO SURGEONS OF CENTRAL PA 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. X-RAY INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642500 59564-L12 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -vs- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H S C Y on behalf of ICE?? -C 0 TOMMASO, ESQ. Attorney for DEFENDANT DE11-0649216 59564-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -vs- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ES Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.15S 133-H DE02-0341482 59564-C03 LOCATION NAME ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL R1.15S 133-H >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY PAGE: 1 DE02-0341482 59564-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SUSQUE ANNA VALLEY SURGERY QTR (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 R ER * * * * at The MCS Groun 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: MICHAEL A. DETOMMASO. ES ADDRESS: 3773 CORPORATF-CTR:_ PKWY CENTER VALLEY, PA 18034 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE C URT: Prothon tary/Cle ivil D?Ision Deputy Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SUSQUEHANNA VALLEY SURGERY CTR 4310 LONDONDERRY RD. SUITE 1 HARRISBURG, PA 17109 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. X-RAY INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642502 59564-L13 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON ofli COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 -VS- FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H J S on behalf f 63^ ICHP,EL A . 4DTkkLSQ% . Attorney for DEFENDANT DE11-0649217 59564-L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ##800 PHILADELPHIA, PA 19103 (215) 246-0900 >>> LOCATION LIST <<< LOCATION NAME ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY PAGE: 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for QUANTUM IMAGING - - - (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: **** SE ATTACHED ER **** at The MCS Group, Inc„ 1601 Market Street Suite 800, %ildelnj», 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: MICHAEL A. DETOMMASO. ES ADDRESS: 3773 CORPORATE _CTR PKWY CENTER VALLEY- PA 18034 TELEPHONE (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Protho rotary/Clerk Div' ion Deputy Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING 2527 CRANBERRY HIGHWAY WAREHAM, MA 02571 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. X-RAY INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642504 59564-L14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 -vs- FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H S on behal of ?L ET6MS0, 4E. Attorney for DEFENDANT DE11-0649218 59564-L15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 MCS on behalf of MICHAEL A. DETOMMASO, E Attorney for DEFENDANT CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 »> LOCATION LIST <<< LOCATION NAME ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY PAGE: 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HIGHMARK. 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 Groin. Inc„ 1601 Market Street, Suite 800Philadelphia 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: MICHAEL A. DETOMMASO, ES ADDRESS: 3773 CORPORATE CTR. PKWY CENTER VALLEY, PA 18034 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE OURT: Proth otary/Cle ivil ivision 0/1'n Deputy Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HIGHMARK, INC. P.O. BOX 890089 CAMP HILL, PA 17089 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. GROUP NO:ZAM207564213, GROUP NO:4809708 Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social security #: 207-56-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642506 59564-L15 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON OAIG?"' COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 -VS- FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H V S on behalf of ??D T SP C r Attorney for DEFENDANT DE11-0649219 59564-L16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -vs- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 >>> LOCATION LIST «< LOCATION-NAME ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY PAGE: 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOU-TH REHAB (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 RIVER **** 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: MICHAEL A. DETOMMASO. ES ADDRESS: 3773 CORPORATE CTR. PKWY CENTER VALLEY. PA 18034 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE UR.T: Prothonotary/Cler vil ision Deputy Date: OF 4- 0% =291 dz.)nL Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HEALTHSOUTH REHAB 175 LANCASTER BLVD P.O. BOX 2016 MECHANICSBURG, PA 17055 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. GROUP NO:ZAM207564213, GROUP NO:4809708 X-RAY INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642508 59564-L16 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 OP ?f .e IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -vs- CASE NO: 04-3528 FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H S on beh?Ua- lf of ??'O? - E ESQ. Attorney for DEFENDANT DE11-0649220 59564-L17 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 MCS on behalf of MICHAEL A. DETOMMASO, ES Attorney for DEFENDANT CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY It PAGE: 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JEAN LAUDI (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: **** SE ATTACHED RIDER **** at The MCS Groin 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: MICHAEL A. DETOMMASO, ES ADDRESS: 3773 CORPORATE CTR. PKWY CENTER VALLEY. PA 18034 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: AWA b t BY THE URT: Prothon tary/Cler i1 D' ision Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR JEAN LAUDIG ALLSTATE INSURANCE CO. 6345 FLANK DR.ST1000 HARRISBURG, PA 17112 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. CLAIM NO: 1554537884-3K7; POLICY NO:05254976804/02 Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic forth, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642510 59564-L17 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON r'k , r OR! COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 -VS- FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H VCH n beha of rn e? DE'dmM ESQ . ' ` j Attorney for DEFENDANT DE11-0649221 59564-L18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -vs- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, E Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 LOCATION NAME ORTHO SURGEONS OF' CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL >>> LOCATION LIST <<< RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY PAGE: 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for AMERICAN LEGION HOME ASSN (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: * * * * SE ATTACHED RIDER * * * * at The MCS Groun 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: MICHAEL A. DETOMMASO. ESQ. ADDRESS: 3773 CORPORATE CTR. PKWY SUITE 180 CENTER VALLEY. PA 18034 TELEPHONE: lam) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE C T: Prothonot ry/Cler Div' ion Deputy io/,f tl Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: AMERICAN LEGION HOME ASSN. 224 W. MAIN STREET MECHANICSBURG, PA 17055 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642512 59564-L18 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA IN THE MATTER OF: ANDERSON PURSUANT TO RULE 4009.22 -VS- FRY COMMUNICATIONS, INC. O`r e COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3S28 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 S on behal of A. ETO E Q.' Attorney for DEFENDANT R1.15S 133-H DE11-0649222 59564-L19 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -v5- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 »> LOCATION LIST «< LOCATION NAME ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL RECORDS REQUESTED MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY PAGE: 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CUNA MUTUAL 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 TD R * * * * at The MC, roue, Inc., 1601 Market Street, Suite 800, P ilad jphia, PA 1910' 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: MICHAEL A. DETOMMASO ESO ADDRESS: 3773 CORPORATE C'TR PKWY SUITE 180 CENTER VALLEY- PA 18034 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothono ary/Cler Divi ( n Date: Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUNA MUTUAL INSURANCE P. 0. BOX 1621 MADISON, WI 53701 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. GROUP NO:207564213 Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642514 59564-L19 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA IN THE MATTER OF: ANDERSON PURSUANT TO RULE 4009.22 -vs- FRY COMMUNICATIONS, INC. f" ORI COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H CS on beha f of tt ??..nn 11 MC L D`Ei S Qr Attorney for DEFENDANT DE11-0649223 59564-L20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 »> LOCATION LIST <<< LOCATION NAME RECORDS TED ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT.HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY PAGE: I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON vs. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (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 ATTAC E R **** 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: MICHAEL A. DETOMMASO ES ADDRESS: 3773 CORPOR ATF C'TR PW WV CENTER VALLEY. PA 18034 TELEPHONE: _ (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURTovil ( ?'Alp Prothon /C' si on Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 »> LOCATION LIST «< PAGE: 1 I LOCATION NAME RECORDS REQUESTED ORTHO SURGEONS OF CENTRAL PA MEDICAL, BILLING, SUSQUEHANNA VALLEY SURGERY CTR MEDICAL, BILLING, QUANTUM IMAGING MEDICAL, BILLING, HIGHMARK, INC. INSURANCE HEALTHSOUTH REHAB MEDICAL, BILLING, JEAN LAUDIG INSURANCE AMERICAN LEGION HOME ASSN. EMPLOYMENT CUNA MUTUAL INSURANCE INSURANCE HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL X-RAY ONLY HOLY SPIRIT HOSPITAL BILLING ONLY AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (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 Groin- Inc , 1601 Market Street, Suite 800, Pbiladell2 i 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: MICHAEL A. DETOMMASO. ES ADDRESS: 3773 CORPORATE CTR. PKWY TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY TH4OURT: Protho otary/C ivi1 ivision Deputy Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HOLY SPIRIT HOSPITAL RADIOLOGY DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. X-RAY INVENTORY Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise.in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642518 59564-L21 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA . .22 ORIC PURSUANT TO RULE 4009 IN THE MATTER OF: ANDERSON COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 10/02/2006 R1.15S 133-H C 4 S on beha f of/??Q?/,?,?y? . D?qIMMASO,uESQ?. VC' Attorney for DEFENDANT DE11-0649225 59564-L22 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -vs- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 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: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/11/2006 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 »> LOCATION LIST <<< PAGE: 1 ' LOCATION NAME RECORDS REQUESTED ORTHO SURGEONS OF CENTRAL PA SUSQUEHANNA VALLEY SURGERY CTR QUANTUM IMAGING HIGHMARK, INC. HEALTHSOUTH REHAB JEAN LAUDIG AMERICAN LEGION HOME ASSN. CUNA MUTUAL INSURANCE HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, INSURANCE MEDICAL, BILLING, INSURANCE EMPLOYMENT INSURANCE MEDICAL RECORDS X-RAY ONLY BILLING ONLY AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON File No. 04-3528 VS. FRY COMMUNICATIONS, INC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (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: MICHAEL A. DETOMMASO. ES ADDRESS: 3773 CORPORATE CTR. PKWY CENTER VALLEY. PA 18034 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE OURT: LIW?7 Prot ho otary/Cl v i I D i s i o n Deputy Date: Seal of the Court C n CC A `11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR HOLY SPIRIT HOSPITAL BILLING DEPT.. 503 N. 21ST STREET CAMPHILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.15S 133-H SU10-0642520 59564-L22 nJ <'?. ??., ?-, _?+ - -- t _^, ?-r, ?-- -. ._y ° ? ?__. .. -X- ,.._ _ .-,-s , _:. ? , ._. =' ?- (^?.? :. ? : 3 d ?? ? V CERTIFICATE :r PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON -v5- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 04/09/2007 ?? b MI DETO O, ESQ. Atto ey for DEFENDANT R1.25 133-H DE11-0680916 59564-L23 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ZLOTOFF & ASSOCIATES WEST SHORE ELKS MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: DONALD R. DORER, ESQ. DAVID S. WISNESKI, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL A. DETOMMASO, 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: 03/19/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.17S 133-H D1902-0358105 59564-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ZLOTOFF & ASSOCIATES (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 Ca=. 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: MICHAEL A. DETOMMASO. ES ADDRESS: 3701 CORPORATE. CM- PKWY TELEPHONE: 1 15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ! i a-, anU7 Seal of the Court BY COURT: A as 1, Prothonotary/Clerk, Civil Divis' Deputy 59564-23 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ZLOTOFF & ASSOCIATES 3600 TRINDLE ROAD CAMP HILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.17S 133-H SU10-0676158 59564-L23 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA' Cs ? PURSUANT TO RULE 4009.22 1 i+ ulAL IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -VS- CASE NO: 04=3528 FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 04/09/2007 d S f M A. DET MMASO, ESQ. l Attorney for DEFENDANT T R1.25 133-H DE11-0680917 59564-L24 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ZLOTOFF & ASSOCIATES MEDICAL, BILLING, AND X-RAY(S) WEST SHORE ELKS EMPLOYMENT TO: DAVID S. WISNESKI, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 03/19/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 Any questions regarding this matter, contact MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.17S 133-H D3302-0358104 59564-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON File No. 04-3528 VS. FRY COMMUNICATIONS, INC. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for _ WEST SHORE ELKS (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 YDER **** at The MCS Grog. Inc-- 1601 Market Street, Suite 800 P ilad Whia, 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: MICHAEL A. DETOMMASO ES ADDRESS: 3701 CORPOR ATE. C TR Px W V TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ?a ci 7- Seal l of the Court BY 59564-24 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WEST SHORE ELKS 108 N. ST JOHNS CHURCH RD CAMP HILL, PA 17011 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.17s 133-H SU10-0676160 59564-L24 t"+ r ;? -si __., - -?;?.? _. N +? -? ' ?. . s ; k? , . ?: ? ._. _? ^„? ?, PWCIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ® 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) (check one) ® Civil Action - Law ? Appeal from arbitration - (other) (Plaintiff) VS. 111 " D. ] a_ FRY t74TIO115, INC (Defendant) VS. The trial list will be called on Octaibeir 16, 2007 and Trials commence on November 13, 2007 Pretrials will be held on Octofer 24. 2007 (Briefs are due 5 days before pretrials No. 04-3528 Term Indicate the attorney who will try case for the party who files this praccipe: David S. idiom, Esquire for Plaintiff, Brenda Anderson Min 9 counsel or otter p?tror Defiant, Jim D. Eash Nicbael A. DeTbwaso, Esquire for Dot, 'w ions, Inc. This case is ready for trial. Signed: Print Name: David S. Wisneshi Date: r- 2 8"' o / Attorney for: Plaintiff c 7Cr" G'? t"43;-;-^^ ' Y ' -rJ t _ r? tv co CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -VS- CASE NO: 04-3528 FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO_, 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: 09/10/2007 `?CS on beha f f ,5/ MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709761 59564-L25 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MICHAEL PECK, M.D. JOHN S. RYCHAK, MD DAVID RAPTOSH,MA JOYNER SPORTS DILLSBURG VETERANS OF FOREIGN E. BERLIN VETERANS OF FOREIGN MICHAEL F. LUPINACCI, M.D. NEW OXFORD SOCIAL CLUB MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT EMPLOYMENT MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: DONALD R. RORER, ESQ. LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DAVID S. WISNESKI, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 08/21/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.41S 133-H D90224571242-691664-C03 CONn O ? 'YLVANIA COUNTY OV CUMBERLAND ANDERSON VS. TO: FRY COMMUNICATIONS, INC. File No. 04-3528 Custodian of Records for MICHAEL PECK M.D. . (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 Crc=. Inc 1601 Market Street. Sine 800philadellphia 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: ADDRESS: TELEPHONE: (215) 246-0400 SUPREME COURT ID #: ATTORNEY FOR: Dafendant BY THE COURT: Date: 3/10107 Seal of the Court 'thonotary/Clerk, Ci ' ivision Deputy 5956425 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MICHAEL PECK, M.D. 3130 GRANVIEW ROAD BLDG. A HANOVER, PA 17331 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 03-01-2006 to the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.41S 133-H SU10-0701200 59564-L25 CERTIFICATE ? , ORIGINA PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -vs- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/10/2007 j? Q?/V? I- L 92!?? 7) MICHAEL A. DETOMMASO, ESQ. / Attorney for DEFENDANT R1.41 133-H DE11-0709762 59564-L26 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SBRVE A SUBPOENA TO PRODUCE DOCUCM6 AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MICHAEL PECK, M.D. JOHN S. RYCHAK, MD DAVID RAPTOSH,MA JOYNER SPORTS DILLSBURG VETERANS OF FOREIGN E. BERLIN VETERANS OF FOREIGN MICHAEL F. LUPINACCI, M.D. NEW OXFORD SOCIAL CLUB MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT EMPLOYMENT MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. DAVID S. WISNESKI, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 08/21/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.41S 133-H D90224311439-69664 -C03 COMMONWEALTH OF.PENNSYLVANIA COUNTSt' Ot VUWERLAND ANDERSON File No. 04-3528 VS. TO: FRY COMMUNICATIONS, INC. Custodian of Records for JOIIN S. RYCHAI- MD (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: **** SRR ATTACHED RIDER **** at The MCS Grmip Inc-- 1601 AtW Steeet, Sots 800, P i1 d y ia. 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: ADDRESS: TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: d oLo-7 Seal of the Court BY THE COURT: thonotary/Clerk, Civi ivision )t?,Jw Deputy 59564-26 EXPLANATION REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN S. RYCHAK, MD 99 NOVEMBER DRIVE CAMP HILL, PA 17011 RE : 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 03-01-2006 to the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, SNOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.41S 133-H SU10-0701202 59564-L26 40... CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/10/2007 / S on behal o MICHAEL A. DETOMMASO, ESQ. / Attorney for DEFENDANT R1.41 133-H D811-0709763 59564-L27 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF : ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 44-3528 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUNBNTS AND THINGS FOR DISCOVERY PURSUANT TO RULX 4009.21 MICHAEL PECK, M.D. JOHN S. RYCHAK, MD DAVID RAPTOSH,MA JOYNER SPORTS DILLSBURG VETERANS OF FOREIGN E. BERLIN VETERANS OF FOREIGN MICHAEL F. LUPINACCI, M.D. NEW OXFORD SOCIAL CLUB MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT EMPLOYMENT MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: DAVID S. WISNESKI, ESQ. LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 08/21/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.41S 133-H D$Ox8l97199B-09664-C03 COMMONWEAL . YLVANIA COUNTY bF CMM ISLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 SUBPOENA TO PRODUCE DOCUMENTS OR THWGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DAVID RAPTOSH A JOYNER SPORTS (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 un_ nc:__ 1601 Market SM=L Suits 800, P ila dg i& 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: ADDRESS: TELEPHONE: (mo) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Date: Seal of the Court S e. ? thonotary/Ckerk, Civil Aision Deputy 59564-27 EXPLANATION REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID RAPTOSH,MA JOYNER SPORTS 4800 LINGELSTOWN RD SUITE 102 HARRISBURG, PA 17112 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, BNOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.41S 133-H SU10-0701204 59564-L27 -W... CER-titid ATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -VS- CASE NO: 04-3528 FRY COMMUNICATIONS, INC. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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 sere the subpoena. DATE: 0910/2007 S ` n be a `o?? l MICHAEL A. DETOMMA.SO, ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709764 59564-L28 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF II?ITENT TO SERVE A SUBPOENA TO PRODUCE DOCMENTS AND THMS FOR DISCOVERY PiTRSQANT TO RIILS 4009.21 MICHAEL PECK, M.D. JOHN S. RYCHAK, MD DAVID RAPTOSH,MA JOYNER SPORTS DILLSBURG VETERANS OF FOREIGN E. BERLIN VETERANS OF FOREIGN MICHAEL F. LUPINACCI, M.D. NEW OXFORD SOCIAL CLUB MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT EMPLOYMENT MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: LISA MARIE COYNE,.ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. DAVID S. WISNESKI, ESQ. MCS on behalf of MICHAEL A. DETOIrMASO, 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: 08/21/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMrMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.41S 133-H D30222371409-69664-C03 COMM9NWEALT110F PENNSYLVANIA COUNTY OV CtUgERLAND ANDERSON File No. 04-3528 VS. FRY COMMUNICATIONS, INC. TO: Custodian of Records for DILLSBURG VETS ANS OF FO RI rN (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 C=M- Inc_- 1601 Market Stmt Suite 800- PhilacidpWa. 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: ADDRESS: TELEPHONE: (2155) 2A64)900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 8110107 Seal of the Court BY THE COURT: Mthonotary/Clerk, • Civil vision -AMY 71 Deputy 59564-28 EXPLANATION 6? REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DILLSBURG VETERANS OF FOREIGN WARS 22 FRANKLIN ST. DILLSBURG, PA 17019 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, EHOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.41S 133-H SU10-0701206 59564-L28 ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -VS- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/10/2007 ' o? behalf of / s MICHAEL A. D?O. ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709765 59564-L29 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMMktA 1'D IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. MICHAEL PECK, M.D. JOHN S. RYCHAK, MD DAVID RAPTOSH,MA JOYNER SPORTS DILLSBURG VETERANS OF FOREIGN E. BERLIN VETERANS OF FOREIGN MICHAEL F. LUPINACCI, M.D. NEW OXFORD SOCIAL CLUB COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT EMPLOYMENT MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: LISA MARIE.COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. DAVID S. WISNESKI, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 08/21/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.41S 133-H D90222971989-CSM64-C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF C°,"ERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 043528 TO: Custodian of Records for E BERLIN VETERANe n? ?nQ ?TrN (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 Jim MCS Ground..1601 Market Street Suitt 800- MaAelphia. 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: ADDRESS: TELEPHONE: ,(215) 2464)900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: A lC?o7. Seal of the Court BY THE COURT: thonotary/Clerk, Civil D ion &kICA. 4, " A &4tJ Deputy 59564-29 EXPLANATION Of REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: E. BERLIN VETERANS OF FOREIGN WARS 107 LOCUST ST. E. BERLIN. PA 17316 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.41s 133-H SU10-07012os 59564-L29 CERTIFICATE ORIGINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANDERSON TERM, CUMBERLAND -VS- FRY COMMUNICATIONS, INC. CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/10/2007 if of /6/?C o `be J/ r.C3-?y MICHAEZ A. DETOMMASO, ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709766 59564-L30 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO SERVE A SOP-OM TO PRODUCE DOCMMXTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MICHAEL PECK, M.D. JOHN S. RYCHAK, MD DAVID RAPTOSH,MA JOYNER SPORTS DILLSBURG VETERANS OF FOREIGN E. BERLIN VETERANS OF FOREIGN MICHAEL F. LUPINACCI, M. D. NEW OXFORD SOCIAL CLUB MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT EMPLOYMENT MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: LISA MARIE.COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. DAVID S. WISNESKI, ESQ. MCS on behalf of MICHAEL A. DETOMMASO, 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: 08/21/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.41S 133-H D30221S71209-699664-CO3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDERSON VS. FRY COMMUNICATIONS, INC. File No. 04-3528 TO: Custodian of Records for- -- MICHAEL F. LUINACCI, M.D. (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 ATTACHM RIDER **** _ at The MCS Group Inc-- 1601 Market Su=L Sum $44. j hiladelpWa PA 1 o 103 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 maldng 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: ADDRESS: TELEPHONE: (215) 2464PM SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 311610 Seal of the Court BY THE COURT: /j "- P- - !Clerk, Civil ion i6thmotarY I &j,,,. _ 4, .,k A-1. Deputy 59564-30 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MICHAEL F. LUPINACCI, M.D. 175 LANCASTER AVENUE P.O. BOX 2028 MECHANICSBURG, PA 17055 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. FILM INVENTORTY Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : BRmwA M. AND=sON 475 SADDLE BRIDGE ROAD, BNOLA, PA 17025 Social security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.41s 133-H SU10-0701210 59564-L30 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF : ANDERSON -VS- FRY COMMUNICATIONS, INC. ORIGINAL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 04-3528 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL A. DETOMMASO, 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: 09/10/2007 j `? on be l? of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT R1.41 133-H DE11-0709767 59564-L31 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANDERSON -VS- FRY COMMUNICATIONS, INC. COURT OF COMMON PLEAS TERM, CASE NO: 04-3528 NOTICE OF INTENT TO S06VE A SUBFORNA TO PRODUCS DOCUMMIS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MICHAEL PECK, M.D. JOHN S. RYCHAK, MD DAVID RAPTOSH,MA JOYNER SPORTS DILLSBURG VETERANS OF FOREIGN E. BERLIN VETERANS OF FOREIGN MICHAEL F. LUPINACCI, M.D. NEW OXFORD SOCIAL CLUB MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT EMPLOYMENT MEDICAL, BILLING, AND X-RAY(S) EMPLOYMENT TO: LISA MARIE COYNE, ESQ., PLAINTIFF COUNSEL DONALD R. DORER, ESQ. DAVID S. WISNESKI, ESQ. MCS on behalf of MICHAEL A. DETObMASO, 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: 08/21/2007 CC: MICHAEL A. DETOMMASO, ESQ. - 185118 DEREK HURLBERT - 450068219001 MCS on behalf of MICHAEL A. DETOMMASO, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 R1.41S 133-H DS0282S719v&-&9664 -C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMALRLAND ANDERSON VS. TO: 'FRY COMMUNICATIONS, INC. File No. 04-3528 Custodian of Records for NEW OXFO S AT. C LI (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 mxm_ inc.- 1601 adol gtmt Suite 800 P it &"16 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 THETOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: _ (215) 2464)900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Date: $1_IO?tyl? Seal of the Court [Plothonotary/Clerk, Civil vision ??AA.- e. Deputy • 59564-31 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NEW OXFORD SOCIAL CLUB 200 W. GOLDEN LANE NEW OXFORD, PA 17350 RE: 59564 BRENDA M. ANDERSON Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : BRENDA M. ANDERSON 475 SAMPLE BRIDGE ROAD, ENOLA, PA 17025 Social Security #: XXX-XX-4213 Date of Birth: 09-22-1962 R1.41s 133-H SU10-0701212 59564-L31 c t W SUSAN SMITH LLOYD, ESQUIRE Attorney I.D. No: 54484 HENDRZAK & LLOYD 3701 Corporate Center Parkway, Suite 100 Center Valley, PA 18034 (610) 709-8705 BRENDA M. ANDERSON V. JESSE D. EASH & FRY COMMUNICATIONS, INC. ATTORNEY FOR DEFENDANT, FRY COMMUNICATIONS, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 04-3528 TRIAL BY JURY OF 12 DEMANDED WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Defendant, Fry Communications, Inc., in the above-captioned matter. Michael A. DeTommaso, Esquire Attorney for Defendant, Fry Communications, Inc. ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Defendant, Fry Communications, Inc., in the above-captioned matter. AN SMITH LL Y , SQUIRE Attorney for Defendant Fry Communications, Inc. C ',_? Cl) BRENDA M. ANDERSON, Plaintiff V. JESSE D. EASH and FRY COMMUNICATIONS, INC., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 04-3528 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above-captioned action settled, ended and discontinued. Respectfully submitted, NAVITSKY, OLSON & WISNESKI LLP w David S. W sneski, Esquire I.D. No. 58796 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 717/541-9205 Counsel for Plaintiffs Date: October 24, 2007 ar CD 71 .r=-