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HomeMy WebLinkAbout11-33730:','- TNELP HON OTARY 201 I HAR 30 AM 1 f : 42 CUMBERLAND COUNTY PENNSYLVAN11A W. Scott Henning Attorney ID# 32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff(s) Fax : (717) 233-3029 E-mail: Henning@hhrlaw.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2011 _ 3;5-7 ? Civil Action (XX) Law ( ) Equity Diana M. Howey and David J. Howey, Sr., her husband 240 Eden Drive Etters, PA 17319 Plaintiff(s) & Address(es) Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwarded to ( )Attorney (XX)Sheriff W. Scott Henning Handler. Henning & Rosenberg. LLP 1300 Linglestown Road Suite 2 Harrisburg. PA 17110 (717) 238-2000 Name/Address/Telephone No. of Attorney : Melanie L. Allbritton : 304 Market St. : Apt. #5 : Lemoyne, PA 17043 versus Signature of Supreme CC Date: March 28, 2011 WRIT OF SUMMONS 32298 TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. v Zfl )- L 3/3t??1 Prothon ry Date: by 94 Deputy ( ) Check here if reverse is used for additional information PROTHON. - 55 0134895704.1-B14 LAW OFFICES OF TWANDA TURNER-HAWKINS REBECCA E. JELLEN, ESQUIRE Identification No. 87005 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5492 DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband V. MELANIE L. ALLBRITTON 1 :10 ' co - C) ATTORNEY FOR DEFENDANI* ° Melanie L. Allbritton zC -Z h? COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 2011-3373 ENTRY OF APPEARANCE TO THE CLERK: Please enter my Appearance on behalf of Defendant, Melanie L. Allbritton in reference to the above captioned case. REBECCA E. JELL , ES UIRE Attorney for Defen t Melanie L. Allbritton I hereby certify that I have served a copy of this paper upon all other parties or their attorney of record by Regular First Class Mail on November 7, 2011. 0134895704.1-B14 LAW OFFICES OF TWANDA TURNER-HAWKINS REBECCA E. JELLEN, ESQUIRE Identification No. 87005 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5492 DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband V. MELANIE L. ALLBRITTON ATTORNEY FOR DEFENDAN? Melanie L. Allbritton =:;o >'-- cn y C7 . o ?C:) O COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 2011-3373 PRAECIPE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a Rule upon Plaintiffs, Diana M. Howey and David J. Howey, Sr., to file a Civil Action within twenty (20) days hereof or suffer t ntry of a Judgment of Non Pros. REBECCA E. LL N, ESQUIRE Attorney for D en t Melanie L. Allbri on RULE TO FILE CIVIL ACTION AND NOW, this ?& day of NOV. , 2011, a Rule is hereby granted upon Plaintiffs to file a Civil Action within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. PROTHONOTARY 0134895704.1-B 14 LAW OFFICES OF TWANDA TURNER-HAWKINS REBECCA E. JELLEN, ESQUIRE Identification No. 87005 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5492 DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband V. MELANIE L. ALLBRITTON r l Cif . r C-D W ATTORNEY FOR DEFENDANTr-? Melanie L Allbritton Q o . C^ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 2011-3373 DEMAND FOR JURY TRIAL TO THE CLERK: Defendant, Melanie L. Allbritton, Demands a Jury Trial of twelve (12) in reference to the above captioned case. I hereby certify that I have served a copy of this paper upon all other parties or their attorney of record by Regular First Class Mail on November 7, 2011. Attorney Tor UeTenaani Melanie L. Allbritton 1 • 0134895704.1-B14 LAW OFFICES OF TWANDA TURNER- HAWKINS REBECCA E. JELLEN, ESQUIRE Identification No. 87005 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5492 DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband V. MELANIE L. ALLBRITTON O 9 tiE FiD7NC,? try' .. ATTORNEY FOR DEFENDANT Melanie L. Allbritton 2012 MAY 14 PM 12: ",13 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 2011-3373 NOTICE TO PLEAD TO: Diana M. Howey and David J. Howey, Sr., Plaintiff C/O W. Scott Henning, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburgh, PA 17110 YOU ARE HEREBY NOTIFIED AND REQUIRED TO FILE A WRITTEN RESPONSE TO THE WITHIN ANSWER AND NEW MATTER OF DEFENDANT, MELANIE L. ALLBRITTON, TO PLAINTIFF'S COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. DATED: h 0 A 0134895704.1-B 14 LAW OFFICES OF TWANDA TURNER- HAWKINS REBECCA E. JELLEN, ESQUIRE Identification No. 87005 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5492 ATTORNEY FOR DEFENDANT Melanie L. Allbritton DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband V. MELANIE L. ALLBRITTON COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 2011-3373 DEFENDANT'S ANSWER TO COMPLAINT AND NEW MATTER Defendant, Melanie L. Allbritton, by and through the undersigned counsel, answer(s) the Plaintiff's Complaint as follows: 1. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 2. DENIED AS STATED. Answering Defendant currently resides at 304 Market Street, Apartment 9, Lemoyne, Cumberland County, Pennsylvania. 3. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 4. ADMITTED in part, DENIED in part. It is ADMITTED only that on April 9, 2009, Answering Defendant was the operator of a 1999 Chevrolet Cavalier, with a Pennsylvania Registration. The remainder of the averment is DENIED pursuant to Pa. R.C.P. 1029(e). 5. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 6. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 7. ADMITTED in part, DENIED in part. It is ADMITTED that on April 9, 2009, Answering Defendant was traveling on Third Street. The remainder of the averment is DENIED pursuant to Pa. R.C.P. 1029(e). 8. DENIED pursuant to Pa. R.C.P. 1029(e). 9. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 10. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. COUNT I. - NEGLIGENCE 11. DENIED. Answering Defendant incorporates by reference the responsive pleadings set forth in the previous paragraphs of Defendant's Answer as though same were fully set forth at length. 12. (Sub-Paragraphs a-k) DENIED pursuant to Pa. R.C.P. 1029(e). In the alternative, DENIED as the averments contained in the corresponding paragraph of Plaintiffs' Complaint are denied as conclusions of law to which no responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure. Strict proof thereof is demanded. 13. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 14. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 15. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 16. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 17. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 18. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 19. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. COUNT H. - LOSS OF CONSORTIUM 20. DENIED. Answering Defendant incorporates by reference the responsive pleadings set forth in the previous paragraphs of Defendant's Answer as though same were fully set forth at length. 21. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 22. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. 23. DENIED pursuant to Pa. R.C.P. 1029(e). By way of further answer, DENIED. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in the corresponding paragraph of Plaintiffs' Complaint. Said averments are therefore denied. NEW MATTER AFFIRMATIVE DEFENSES 24. Financial Responsibility Law All causes of action and/or claims as set forth in all Civil Action(s)/Complaints(s) are limited, governed, barred, and/or restricted by the terms of the Pennsylvania Motor Vehicle Financial Responsibility Law of 1984, 75 Pa. C.S.A. 1701, et seq., as amended by Act 6 of 1990, the relevant provisions of which are incorporated by reference herein as though the same were fully set forth at length. 25. Limited Tort-ACT 6 All causes of action and/or claims as set forth in all Civil Actions/Complaints are limited, governed, barred, and/or restricted by the terms of the Pennsylvania Motor Vehicle Financial Responsibility Law of 1984, 75 Pa. C.S.A. 1701, et seq., as amended by Act 6 of 1990, the relevant provisions of which are incorporated by reference herein as though the same were fully set forth at length, including but not limited to the "limited tort" provisions of Section 1705, and in accordance with the "tort option" chosen and/or elected in the policy of insurance purportedly providing coverage for the accident in question. 26. Set Off and/or Credit Answering Defendants have a right to a credit or set off in the amount of any underinsured motorist benefits secured by Plaintiff, against any jury verdict or award which may be entered against Answering Defendant. 27. Admissibility of Medical Expenses and Wages The admissibility of the Plaintiff's medical expenses and/or wage loss is barred and/or accordingly limited by the applicable provisions of he Pennsylvania Motor Vehicle Financial responsibility Law, as amended, and more specifically the collateral source rule of 75 Pa.C.S.A. Section 1722. WHEREFORE, Defendant, Melanie L. Allbritton demands Judgment in her favor and against all parties. VERIFICATION Rebecca E. Jellen, Esquire, states that she is the attorney for the within named Melanie L. Allbritton, and the facts set forth in the foregoing pleading are true and correct to the best of her knowledge, information, and belief; and this statement is made subject to the penalties of 18 Pa. C. §4904, relating to unworn falsification to authorities. CERTIFICATE OF SERVICE I do hereby certify that on May 10, 2012 service of a true and correct copy of the within pleading was made on all relevant parties or their counsel of record pursuant to Pa.R.C.P. 440 by means of first class mail at the following address: W. Scott Henning, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburgh, PA 17110 Our File No. 0134895704.1-B 14 LAW OFFICES OF TWANDA TURNER- HAWKINS REBECCA E. JELLEN, ESQUIRE Identification No. 87005 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5492 DIANA M. HOWEY AND DAVID J. HOWEY, SR., HER HUSBAND V. MELANIE L. ALLBRITTON ATTORNEY FOR DEFENDANT Melanie L. Allbritton COURT OF COMMON PLEAS OF CUMBERLAND COUNTYC., C NO. 2011-3373 am Zt:a ?C-- Certificate of Service -a TO THE CLERK: s 3 W I, Rebecca E. Jellen, Esquire, hereby certify that a true and correct copy of Defendant's Interrogatories Addressed to Plaintiff, Diana M. Howey; Defendant's Request for Admissions Directed to Plaintiff, Diana M. Howey with Accompanying Interrogatories; Defendant's Request for Production of Documents Directed to Plaintiff, Diana M. Howey; and Defendant's Loss of Consortium Interrogatories directed to Plaintiff, and David J. Howey, were served this date by United States Mail, First Class, postage prepaid, upon: W. Scott Henning, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburgh, PA 17110 C -7" ;:.. Q •?•+}? C4 'R'^r Dated: May 10, 2012 DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband, Plaintiffs V. MELANIE L. ALLBRITTON, Defendant - IN THE COURT OF COMMON PLYyCUMBERLAND COUNTY, PENNSa IVIg ? NO. 2011- 3373 CIVIL ACTION - LAW PLAINTIFFS' REPLY TO NEW MATTER AND NOW, comes the Plaintiffs, Diana M. Howey and David J. Howey, Jr., by and through their attorney, HANDLER, HENNING & ROSENBERG, LLP, by W. Scott Henning, Esquire, and responds to the Defendant's allegations of New Matter as follows: 24. Denied. The allegation set forth in paragraph 24 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiffs acknowledge that they will be bound by any provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law that the Honorable Court deems properly applicable to the subject cause of action. 25. Denied. The Plaintiffs selected the Full Tort option, and hence, the allegations set forth in Paragraph 25 are not applicable to the subject cause of action. 26. Denied. The allegation set forth in paragraph 26 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiffs assert that they have not presently engaged in any settlement of any potential Underinsured Motorist coverage. 27. Denied. The allegation set forth in paragraph 27 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiffs acknowledge that they will be bound by any provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law that the Honorable Court deems properly applicable to the subject cause of action. WHEREFORE, Plaintiffs Diana M. Howey and David J. Howey, Sr., requests the Honorable Court to enter judgment in their favor and against the Defendant, Melanie L. Allbritton, for the relief set forth in their Complaint. Respectfully submitted, HANDLER, RENNIN "OSENBERG, LLP By: W. Scott+k-Kh Supreme Court ID#32298 1300 Linglestown Road - Suite 2 Harrisburg, PA 17110 (717)238-2000 Dated , y Attorney for Plaintiff VERIFICATION PURSUANT TO PA R.C.P. NO. 1024 (c) W. SCOTT HENNING, ESQUIRE, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that the Plaintiff was not available to execute the Verification so as to comply with the time deadline within which to file this document and that this statement is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. Date: W. SCOTT HENNING, ESQ IR _Ir DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband, Plaintiffs V. MELANIE L. ALLBRITTON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011- 3373 CIVIL ACTION - LAW CERTIFICATE OF SERVICE On the 16th day of May, 2012, 1 hereby certify that a true and correct copy of Plaintiffs' Reply to New Matter was served upon the following by depositing in U.S. Mail: Rebecca E. Jellen, Esq. Law Offices of Twanda Turner-Hawkins Iron Run Corporate Center 7535 Windsor Dr. Suite 101-B Allentown, PA 18195 WSH/tgd HANDLER, HENNING & ROSENBERG, LLP W. Scott Henning U13489~704 l-Bl~ LAW OFFICES OF TWANDA TURNER-HAWKINS REBECCA E. JELLEN, ESQUIRE; Identification No. 87005 Iron Run Corporate Center 7535 Windsor Driti~e, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5492 ATTORNEY FOR DEFENDANT ::` Melanie L. Allbritton ~ ~~~~ `_~~~ ;~~; T, ~-v -_ ~:`. ~~, »~ ~ COURT OF COMMON PLEAS _-+ OF CUMBERLAND COUNTY ^.,'. ~=~; ~_:~ '~, ::;, .tan ~{'Y, .~. .A.,.. cy DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband ~' MELANIE L. ALLBRITTON NO. 2011-3373 WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY": Kindly withdraw my appearance on behalf of Melanie L, Allbritton in reference to the above-captioned case. T __. // E CCA E. JEL ~ LJIRE 0134E;95704.1 -614 LAW OFFICES OF TWANDA TURNER- HAWKINS LAURIE B. TILGHMAN, ESQUIRE Identification No, 89936 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone; (610) 398-5492 DIANA M. HOWEY and DAVID J. HOWEY, SR., her husband ATTORNEY FOR DEFENDAN~I` Melanie L. Allbritton '~ , ,.~ .. s, t..c~ COURT OF COMMON PLEAS ~'~ -~ -~' ~, OF CUMBERLAND COt1NTY ~ ``"~ ~" - NO. 2011-3373 ~ ~ ~~--~ MEL.AME L. ALLBRITTON ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my Appearance on behalf of Melanie L. Allbritton in reference to the above- captioned case.. '~ yl '•' LAURIE B. TILGHMAN, ESQUIRE Attorney for Defendant Melanie L. Allbritton IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HONEY p Vs. C NO. 2011-3373 `G ALI;BRITTON Z �rn C CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA v n c )°-6 PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena (s) for documents and things pursuant to Rule 4009 .22 LAURIE B TILGHMAN, ESQUIRE .certifies that: 1 . A Notice of Intent to Serve the Subpoena (s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2 . A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3 . No objection to the subpoena(s) has been received, and 4 . The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s) Date: 05/17/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 610-398-5480 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Theresa Deni MLR File #: M410906 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HONEY Vs . ALLBRITTON No. 2011-3373 TO: W SCOTT HENNING, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one (s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 04/26/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Theresa Deni Enc (s) : Copy of subpoena(s) Counsel return card File #: M410906 rrwoonNWFmum OF PENNSYLVANIA 00[JNry OF cumBERLAND HONEY k 'Vs . File No. 2011-3373 ALLBRITTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 MAGNETIC IMG CTR, 4665 TRINDLE RD, MECHANICSBURG PA 17050 TO: (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fol lowing documents or, th3,ng�• rT.AT71TrA f LL L'� LiTiZ�l DU at MEDICAL LEGAL REPRODUCTIONS INCA 0 DISSTON ST. , • . P —�--- (A ress) You may deliver or mail legible copies of the documents or produce things requested b� this subpoena, together with the certificate of compliance, to the party making thi; request at the address listed above. You have the right to seek in advance the rea.onablc 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 thin subpoena may seek a court order c=pe l l i ng you to ca. l y with it. THIS SUBPOENA WAS ISSUED AT THE REOMST OF THE FOLLOWING PERSON: NAME: LAURIE B TILGHMAN, ESQ ADDRESS: 7S3 S WINDSOR DR 18195 TELEPHONE: SUPREME OOURT ID # . 215-335-32 ATTORNEY FOR: DEFENDANT BY THE COURT: M410906-01 DATE: 3.1 Prot y/Cler k, Civil Division Seal of the Court • Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA HONEY VS14. No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: MAGNETIC IMG CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: DIANA HONEY ADDRESS : 240 EDEN DR ETTERS ,PA DATE OF BIRTH: 04/28/53 SSAN: XXXXX8610 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN I RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. I NO DOCUMENTS AVAILABLE.- I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS PATIENT BILLING X-RAYS RECORDS / XRAYS have been destroyed Date AutHorized signature for MAGNETIC IMG CTR CUMBERLAND M410906-01 SIGN AND RETURN THIS PAGE rruamwFAT.Tr4 or PENNSYLVANIA COUNTY OF CUMBERLAND HONEY *Vs. 2011-3373 File No. ALLBRITTON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 WELLSPAN MED GRP, 1790 OLD TRAIL RD,, ETTERS PA 17319 TO: (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docLrroents ors]EE'% ACBED ADDENDUM at MEDICAL L I EGAL REPRODUCTIONS Inc, 4v4u V.LSST0N ST. , PH!LA. , P* (Address) You may deliver or mail legible copies of the documents or produce things requested t� this subpoena, together with the certificate of ccrm 1 i ance, to the party making thin request at the address listed above. You have the right to seek in advance the rea^onablE- cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde;- cxxrp6lling you to carrply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LAURIE B' TILGHMAN, ESQ ADDRESS: 7535 WINDSOR DR A�131.BNTQWN; Dr 18195 TELEPHONE: 215-335-3212 SUPREME COURT ID ATTORNEY FOR: -DEFENDANT BY THE COURT: M410906-02 Protho, t /Clerk, Civil Division X A DATE: Seal of /the(do rt Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA HONEY Vs . No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: WELLSPAN MED GRP ANY AND ALL RECORDS PRE & POST 4/9/09 MVA. PERTAINING TO: NAME: DIANA HONEY ADDRESS : 240 EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN; XXXXX8610 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS PATIENT BILLING X-RAYS RECORDS / XRAYS have been destroyed Date Authorize signature for WELLSPAN MED GRP CUMBERLAND M410906-02 SIGN AND RETURN THIS PAGE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HOWEY 4..= r- --1 vs . _ -,:; NO. 2011-33731x=° ALLBRITTON ;a: CERTIFICATE = c°' , PREREQUISITE TO SERVICE OF A SUBPOENA .<c, . PURSUANT TO RULE 4009.22 7'= As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009 .22 LAURIE B TILGHMAN, ESQUIRE certifies that: 1 . A Notice of Intent to Serve the .Subpoena (s) with a copy of the subpoena(s) attached thereto was mailed or delivered to . each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2 . A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3 . No objection to the subpoena(s) has been received, and 4 . The subpoena (s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s) . Date: 05/17/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B : 4.."...A(1.,, ALLENTOWN, PA 18195 610-398-5480 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Theresa Deni MLR File '#: M410906 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HOWEY Vs. ALLBRITTON No. 2011-3373 TO: W SCOTT HENNING, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one (s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 04/26/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO': MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Theresa Deni Enc (s) : Copy of subpoena(s) Counsel return card File #: M410906 P. • • cCt4 DNW;<ALTH flF PE NSYLVANr1 COUNTY OF CkIRERIAND • HOWEY •• Vs. • File No. 2011-3373 • ALLBRITTON • • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 • MAGNETIC IMG CTR, 4665 TRINDLE RD, .MECHANICSBURG PA 17050 TO: (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 orsthings. • DENDIJM • at • • • MEDICAL LEGAL REPRODUCTIONS(Adclress)540 DISBTON sT. , You may deliver or mail legible copies of the documents or produce things .requested h, this subpoena, together with the certificate of compliance, to the party making thin request at the address listed above. You have the right to seek in advance the rea^..onable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty ' (20) days after its service, the party serving this subpoena may seek a court order ccxmpe 11 i ng, you to cortp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: • Nye: LAURIE B TILGHMAN, ESQ • • ADDRESS: 7 1 S WINDSOR DR ALLENTOWN, PA 18195 • TELEPHONE: SUPREME COURT ID # 215-335-321Z ATTORNEY FOR: DEFENDANT • BY THE COURT: M410906-01 Prothonotary/Clerk, Civil Division DATE: Seal of the Court Deputy • (Eff. 7/97) • ADDENDUM TO SUBPOENA HOWEY Vs. No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: MAGNETIC IMG CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: DIANA HOWEY ADDRESS: 240 EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN: XXXXX8610 • CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for MAGNETIC IMG CTR CUMBERLAND M410906-01 ** * SIGN AND RETURN THIS PAGE *** COMMONWEALTH OF PENNSYLVANIA comm OF CUMBERLAND • • HOWEY • Vs. • File No. 2011-3373 ALLBRITTON • SUBPOENA TO PRODUCE DOCUMENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 WELLSPAN MED GRP, 1790 OLD TRAIL RD, ETTERS PA 17319 TO: _ (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 ors 'g. i'T ce- B—A ENDUM ---- • at MEDICAL LEGAL REPRODtCTION8 INC, 4940 DISSTON ST. , PUMA. , Per---------- (Address) You may deliver or mail legible copies of the documents or produce things requested t* this subpoena, together with the certificate of carpliance, 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 orde. cx i pel l i ng you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLONING PERSON: NAME: • LAURIE B TILGHMAN, ESQ ADDRESS: 7535 WINDSOR DR „T T ENTOWN ' PA 18195 TELEPHONE: 21b-335-3.12 SUPREME COURT ID * ATTORNEY FOR: DEFENDANT BY THE COURT: M410906-02 Prothonotary/Clerk, Civil Division DATE: Seal of the Court — Deputy (Eff,. 7/97) ADDENDUM TO SUBPOENA HOWEY Vs. No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: WELLSPAN MED GRP ANY AND ALL RECORDS PRE & POST 4/9/09 MVA. PERTAINING TO: NAME: DIANA HOWEY ADDRESS: 240 EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN: XXXXX8610 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS AREATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for WELLSPAN MED GRP CUMBERLAND M410906-02 ** * SIGN AND RETURN THIS PAGE * * * IN THE COURT OF COMMON PLEAS OF CUMBERLAND CqUTA�T mm HOWEY -g NO. 2011-3373!�:p =,-rt ALLBRITTON )>C-) = CERTIFICATE 5 ' A-: PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009 .22 LAURIE B TILGHMAN, ESQUIRE certifies that: 1 . A Notice of Intent to 'Serve the Subpoena(s) with a copy of the subpoena (s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2 . A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3 . No objection to the subpoena(s) has been received, and 4 . The subpoenas) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena (s) . Date: 09/23/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 610-398-5480 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Theresa Deni MLR File #: M414498 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT' HOWEY Vs. ALLBRITTON No. 2011-3373 TO: W SCOTT HENNING, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena (s) identical to the one (s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 08/30/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR .SUITE 101-B ALLENTOWN, PA 18195 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Theresa Deni Enc (s) : Copy of subpoena(s) Counsel return card File # : M414498 I CK,1D1,MEALi�. LJ COUJNrY OF HOWEY Vs . File No. 2011-3373 ALLBRITTON , ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 WELLSPAN IMAGING CTR, 37 MONUMENT RD #101, YORK PA 17403 TO: (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 9XITTAICHER-ADDENDUM ,r D at _ _ ----- MEDICAL LEGAL REPRODUCTIONS(AcW§s�940 DISSTON ST. , PHILA. , PA You may deliver or mail legible copies of the documents or produce things requested t� th i s subpoena, together with the certificate of crnp l i ance, to the party making th i request at the address listed above. You have the right to seek in advance the rea�onablE cost of preoa.-i ng the oo l es 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 'thin, subpoena tray seek a court orde;- cx-mpe l l i ng you to comp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LAURIE B TILGHMAN, ESQ ADDRESS: _ 7535 WINDSOR DR :PffibENTE)WN, PA 18195 TELEPHONE: 215-335- SUPREhE COURT I D ATTORNEY FOR: DEFENDANT BY THE C OL RT: M414498-01 j I) `Q Prothonotary/clerk, Civil Division DATE: J !J Seal of the Court �y (Eff. 7/97) ADDENDUM TO SUBPOENA HOWEY Vs . No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: WELLSPAN IMAGING CTR ANY AND ALL DIAGNOSTIC STUDIES INVOLVING THE LUMBAR. SPINE INCLUDING THE STUDY PERFORMED ON 10/25/12 . TO INCLUDE CORRESPONDING RADIOLOGY REPORTS, PATIENT REGISTRATION, HISTORY AND INSURANCE FORMS . ALL DIAGNOSTIC STUDIES PREFERRED ON CD. PERTAINING TO: NAME: DIANA HOWEY ADDRESS : 240 EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN: Y-XXXX8610 ORIGINAL X-RAYS REQUESTED FOR PRIOR Afjpp� AL CERTIFIED.PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records treat, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following -documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for WELLSPAN IMAGING CTR CUMBERLAND M414498-01 * * * SIGN AND RETURN THIS PAGE r ` OF P YLy-.N. a COUNTY OF CUMBERLAM HOWEY Vs . File No. 2011-3373 ALLBRITTON ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MAGNETIC IMAGING CTR, 4665 E TRINDLE RD, MECHANICSBURG PA 17050 TO: (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 orS + gATTA +R—AD at _ ��NN MEDICAL LEGAL REPRODUCTIONS(Addre§st940 DISSTON ST. , PHILA. , PA You may deliver or mail legible copies of the docements or produce things requested t� this subpoena, together with the certificate of ccanpliance, to the party making thi request at the address listed above. You have the right to seek in advance the rea.onablE St of ranar i n e --- o n .d h things sought. the .�3 ^s or ^.eltG t r„ to:e <.e; , S he_ . If you fail to produce the documents or things required by this subpoena within twenty (20` days after its service, the party serving thin, subpoena may seek a court orde;- cxsnpe l 1 i ng you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LAURIE B TILGHMAN, ESQ ADDRESS: _ 7535 WINDSOR DR 18195 TELEPHONE: 215-335-32= SUPREME OOURT ID # ATTORNEY FOR: DEFENDANT BY THE COURT: : M414498-02 Q ProthonotaryJC:lerk, C DATE-,— ✓ Seal of the Court �- Deputy (Eff. 7/97) 0 ADDENDUM TO SUBPOENA HOWEY Vs . No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CTR ANY AND ALL DIAGNOSTIC STUDIES INVOLVING THE LUMBAR SPINE INCLUDING THE STUDY PERFORMED ON 5/8/09 . TO INCLUDE CORRESPONDING RADIOLOGY REPORTS, PATIENT REGISTRATION, HISTORY AND INSURANCE FORMS. ALL DIAGNOSTIC STUDIES -PREFERRED ON CD. PERTAINING TO: NAME: DIANA HOWEY ADDRESS : 240 EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN: XXXXX8610 ORIGINAL X-RAYS REQUESTED PROVIDE .A,. LIST OF FILMS FOR PRIOR APPROVAL CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ ) RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ) NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for MAGNETIC IMAGING CTR CUMBERLAND M414498-02 * * * SIGN AND RETURN THIS PAGE IN THE COURT OF COMMON PLEAS OF CUMBERLAND CgU1,�TY HOWEY Vs. CM m NO. 2011-3373�' Q° ALLBRITTON D c-) X ?o do CERTIFICATE z PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 LAURIE B TILGHMAN, ESQUIRE certifies that: 1 . A Notice of Intent to 'Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2 . A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3 . No objection to the subpoena(s) has been received, and 4 . The subpoena (s) which will be served is identical to the subpoena (s) which is attached to the Notice of Intent to Serve the Subpoena(s) . Date: 09/23/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 610-398-5480 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET :r . PHILADELPHIA PA 19135 (215) 335-3590 By: Theresa Deni MLR File #: M414498 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HOWEY Vs. ALLBRITTON No. 2011-3373 TO: W SCOTT HENNING, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena (s) identical to the one (s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 08/30/13 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Theresa Deni Enc (s) : Copy of subpoena (s) Counsel return card File # : M414498 r - C0W' 'N�,TH OF PE�figy-:%'-ACq?A CO JNrY OF C Uk HOWEY Vs . File No. 2011-3373 ALLBRITTON ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 WELLSPAN IMAGING CTR, 37 MONUMENT RD ##101, YORK PA 17403 TO: (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,S TTACHE,D—ND at +MEDICAL LEGAL REPRODUCTIONS(A %bst940 DISSTON ST. , PHILA. , PA You may deliver or mail legible copies of the documents or produce things requested t� th i is subpoena, together with; the certificate of ccn-p i i ance, to the party making th i request at the address listed above. You have the right to seek in advance the rea,onablE cost of preoe--in-� the wv,.,.i c s Cr p: v+d,.e lC Z ng the things svught,. . if you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving th i:, subpoena may seek a court orde;- cxxnpe l l i ng you to cap 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LAURIE B TILGHMAN, ESQ HESS: _ 7a35 WINDSOR DR ALLENTOWN, - PA 18195 TELEPHONE: 215-33� 5-32= SUPREhE COURT I D # _ ATTORNEY FOR: DEFENDANT BY THE COURT: M414498-01 ������ ! �/ `Q Prothonotary/Clerk, Civil Division DATE a f J Seal of the Court y (Eff. 7/97) M ADDENDUM TO SUBPOENA HOWEY Vs . No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: WELLSPAN IMAGING CTR ANY AND ALL DIAGNOSTIC STUDIES INVOLVING THE LUMBAR SPINE INCLUDING THE STUDY PERFORMED ON 10/25/12 . TO INCLUDE CORRESPONDING RADIOLOGY REPORTS, PATIENT REGISTRATION, HISTORY AND INSURANCE FORMS . ALL DIAGNOSTIC STUDIES PREFERRED ON CD. PERTAINING TO: NAME: DIANA HOWEY ADDRESS : 240 EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN: XXXXX8610 ORIGINAL X-RAYS REQUESTED 'PROVIDE A LIST OF FTg.T�1Lj FOR PRIOR Ap ' O'WiL CERTIFIED.PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for WELLSPAN IMAGING CTR CUMBERLAND M414498-01 * * * SIGN AND RETURN THIS PAGE r (X)U TY OF CUYMEPIjAND HOWEY Vs . File No. 2011-3373 ALLBRITTON ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUIENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MAGNETIC IMAGING CTR, 4665 E TRINDLE RD, MECHANICSBURG PA 17050 TO: (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 SEE ATTAMMI)-ADDENDUM at MEDICAL LEGAL REPRODUCTIONS(AcgeSst940 DISSTON ST. , PHILA. , PA You may deliver or mail legible copies of the documents or produce things requested t, th i is subpoena, together with the certificate of ccsnp l i ance, to the party making th i request at the address listed above. You have the right to seek in advance the rea.onable C^St Of nrepar i ma the —° i es or produc�ng u e '1"%i n9s sou-3"4-. If you fail to produce the documents or things required by this subpoena within twenty (2C), days after its service, the party serving thi) subpoena may seek a court orde;- cxxrpe l 1 i ng you to ccmp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LAURIE B TILGHMAN, ESQ ADDRESS: _ 7535 WINDSOR DR , PA 18195 TELEPHONE: _ 215 335- SUPREhE OOURT ID # ATTORNEY FOR: DEFENDANT BY THE COURT: M414498-02 1 — q)Q Prothonotary/Clerk, C3v 11 O Av is.i on DATE: 5 - ___ Seal of he court – Deputy (Eff. 7/97) J' ADDENDUM TO SUBPOENA HOWEY Vs . No. 2011-3373 ALLBRITTON CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CTR ANY AND ALL DIAGNOSTIC STUDIES INVOLVING THE LUMBAR SPINE INCLUDING THE STUDY PERFORMED ON 5/8/09 . TO INCLUDE CORRESPONDING RADIOLOGY REPORTS, PATIENT REGISTRATION, HISTORY AND INSURANCE FORMS . ALL DIAGNOSTIC STUDIES PREFERRED ON CD. PERTAINING TO: NAME: DIANA HOWEY ADDRESS : 240 -EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN: XXXXX8610 ORIGINAL X-RAYS REQUESTED PROVIDE A LIST OF FILMS FOR PRIOR APPROVAL CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for MAGNETIC IMAGING CTR CUMBERLAND M414498-02 * * * SIGN AND RETURN THIS PAGE 0134895704.1-B14 LAW OFFICES OF KENNETH S. O'NEILL LAURIE B. TILGHMAN, ESQ. ATTORNEY FOR DEFENDANT(S) Identification No. 89936 Melanie L. Allbritton 7535 Windsor Drive, Suite 101-B Allentown, PA 18195 Telephone: (610) 398-5492 c DIANA M. HOWEY and COURT OF COMMON PLEAS r-'- DAVID J. HOWEY, SR., OF CUMBERLAND COUNTY r' ;. her husband te?' ca - --1 V NO. 2011-3373 v° : ti MELANIE L. ALLBRI ION CERTIFICATE OF SERVICE I, Laurie B. Tilghman, Esquire, hereby certify that a true and correct copy of the attached Deposition Notice directed to Plaintiffs, Diana M. Howey and David J. Howey, Sr., was served this date by United States Mail, First Class, postage prepaid, upon: W. Scott Henning,Esq. 1300 Linglestown Road Harrisburgh, PA 17110 Cumberland County Court of Common Pleas Office of the Prothonotary 1 Courthouse Square Carlisle, PA 17013 ".eG6/&? LAURIE B. TILGHMAN, ESQ. Attorney for Defendant(s) Melanie L. Allbritton Date: Monday, January 20, 2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HOWEY, ET AL Vs. ALLBRITTON C.; •••-■ NO. 20113373 r'.3 CD CP CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 C) As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 LAURIE B TILGHMAN, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 03/18/14 MLR File #: R419127 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 610-398-5480 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3653 By: Susan Tyre IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY HOWEY, ET AL Vs. ALLBRITTON TO: W SCOTT HENNING, ESQ (PLAINTIFF) No. 20113373 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 02/25/14 Enc (s) : Copy of subpoena(s) Counsel return card File #: R419127 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101 -B ALLENTOWN, PA 18195 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335 -3653 By: Susan Tyre HOWEY, ET Al Vs. ALLBRITTON COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 20113373 • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 IDS PROPERTY CAS INS CO, PO BOX 19054, GREEN BAY WI 54307 TO: ATTN: UNDERWRITING DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fol lowing documents orsVr9N at MEDICAL LEGAL REPRODUCTIONScowygges$1940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested this subpoena, together with the certificate of compliance, to the party making thi request at the address listed above.' You have the right to seek in advance the rea,3onable 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 thi:i s ubpoena may seek a court orde- compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LAURIE TILGHMAN, ESQ ADDRESS: 7 WTNDSOR DR TELEPI-CNE: AL-L-ENTEWN, DA 18195 SUPREME COURT ID # ) ATTORNEY FOR: 215-335-3212 .DEFENDANT R419127-.01 -- DATE: Sear:of :..‘h (Eff. 7/97) TX.WEY, ET AL Vs. ALLBRITTON ADDENDUM TO SUBPOENA No. 20113373 CUSTODIAN OF RECORDS FOR: IDSPROPERTYCASINS CO DECLARATION PAGE AND SIGNED TORT FORM FOR POLICY AX00732576 IN EFFECT AT TIME OF 4/9/09 LOSS. INSURED: DIANE HOWEY PERTAINING TO: NAME: DIANE HOWEY ADDRESS: 240 EDEN DR ETTERS PA DATE OF BIRTH: 04/28/53 SSAN: XXXXX CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] ATODOCUMENTSAVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for CUMBERLAND R419127-01 IDS PROPERTY CAS INS CO *** SIGN AND RETURN THIS PAGE ***