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HomeMy WebLinkAbout11-3487I IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY ADRIENNE RITTER, Plaintiff, VS. DUANE E. GINGERICH, SR. 2725 Mill Creek Road Dover, PA 17315 and RONALD LEIPART TRUCKING, INC. 1 Vulcan Lane Red Lion, PA 17356 Defendants. CIVIL ACTION - LAW Case No. k`_ 398 Ci Vl I cr) cn , _ M C-n C) 5;cz r, (:5 . c JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and 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 GO FOR LEGAL HELP. COURT ADMINISTRATOR 4ch Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 S Ora uga a S`7 509 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY ADRIENNE RITTER, Plaintiff, VS. CIVIL ACTION - LAW Case No. DUANE E. GINGERICH, SR. 2725 Mill Creek Road Dover, PA 17315 and RONALD LEIPART TRUCKING, INC. 1 Vulcan Lane Red Lion, PA 17356 Defendants. JURY TRIAL DEMANDED NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demanda expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. COURT ADMINISTRATOR 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 -2- IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY ADRIENNE RITTER, Plaintiff, VS. CIVIL ACTION - LAW Case No. DUANE E. GINGERICH, SR. 2725 Mill Creek Road Dover, PA 17315 and RONALD LEIPART TRUCKING, INC. 1 Vulcan Lane Red Lion, PA 17356 Defendants. JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff, Adrienne Ritter, is an adult individual who resides at 5226 Winding Way, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant Duane E. Gingerich, Sr. is an adult individual who resides at 2725 Mill Creek Road, Dover, York County, Pennsylvania. 3. Defendant Ronald Leipart Trucking, Inc. is a business located at 1 Vulcan Lane, in Red Lion, York County, Pennsylvania, that regularly conducts business in Cumberland County. 4. The facts and occurrences hereinafter related took place on or about June 3, 2010 at approximately 2:47 p.m. on Interstate Route 83, near exit 4013, Cumberland County, Pennsylvania. 5. At that time and place, Defendant Duane E. Gingerich was operating a 2000 Freightliner Truck with attached Great Dane Semi-Trailer in a northbound direction on Interstate 83. -3- 6. At that time and place, Defendant Duane E. Gingerich was acting within the course and scope of his employment with his employer, Ronald Leipart Trucking, Inc. 7. While Defendant Duane E. Gingerich was operating the truck on Interstate 83, he failed to slow the truck for traffic on Interstate 83, and the front portion of the truck collided into the rear of a car on Interstate 83. 8. Defendant Duane E. Gingerich then moved into the left hand lane, violently striking the rear of Plaintiff Adrienne Ritter's vehicle, causing both the Plaintiff and Defendant's vehicles to strike the center of the concrete barrier. 9. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Adrienne Ritter are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Duane E. Gingerich, while in the scope of his employment with Ronald Leipart Trucking, Inc. operated his motor vehicle as follows: a. failure to have his vehicle under such control as to be able to stop within the assured clear distance ahead; b. failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; c. failure to apply his brakes in sufficient time to avoid striking the rear of another vehicle; d. failure to travel at a safe speed; e. failure to signal intention to change lanes; f. failure to keep a proper lookout and watch for traffic on the highway; g. failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; h. failure to keep proper and adequate control over his vehicle; and -4- i. driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 12. Plaintiff Adrienne Ritter sustained painful and severe injuries which include but are not limited to injuries to her right knee, elbow, foot, shoulder, and pelvis, as well as pulmonary contusion, right hemothorax, hematoma on right thigh, vertebrae fracture, and rib fracture. 13. By reason of the aforesaid injuries sustained by Plaintiff Adrienne Ritter, she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 14. Because of the nature of her injuries, Plaintiff Adrienne Ritter has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 15. As a result of the aforementioned injuries, Plaintiff Adrienne Ritter has undergone an in the future will undergo great physical and mental sufferings, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 16. As a result of the aforesaid injuries, Plaintiff Adrienne Ritter has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 17. As a result of the aforementioned injuries, Plaintiff Adrienne Ritter has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 18. As a result of the aforementioned injuries, Plaintiff Adrienne Ritter has sustained uncompensated work loss, and claim is made therefor. -5- 19. Plaintiff Adrienne Ritter continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of his lifetime, and claim is made therefor. WHEREFORE, Plaintiff Adrienne Ritter demands judgment against :Defendant Duane E. Gingerich and Defendant Ronald Leipart Trucking, Inc. in an amount in excess of Fify Thousand ($50,000) Dollars exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully submitted, ANGI E c and { PA I.D. No. 47281 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 (717) 238-5610 (Facsimile) THE HERSHEWE LAW FIRM Ed 41ershewe 431 Virginia Avenue Joplin, Missouri 64801 (417) 782-3790 (417) 782-8482 (Facsimile) FRANTZ LAW GROUP Philip Aman Emerald Plaza 402 W. Broadway 9860 San Diego, CA 92101 (619) 233-5945 -6- VERIFICATION I, Adrienne Ritter, Plaintiff, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. WITNESS: ry' ? f Pl 'ntiff Dated: -11- MICHAEL F. FRISBIE, ESQUIRE E-mail: Michael.frisbie@zurichna.com Attorney I.D. No.: 79096 HENDRZAK & LLOYD 3701 Corporate Center Parkway, Suite 100 Center Valley, Pennsylvania 18034 (610) 709-8705 V. DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. ATTORNEY FOR DEFENDANT(S), DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. CUMBERMAND COUNTY COURT OF COMMON PLEAS NO.: 11-3487 Civil TRIAL BY JURY OF 12 DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendants, DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. HENDRZAK & LLOYD W A XA ? ?- Michael F. Frisbie, Esquire Attorney for Defendants ('r4? ? Cl'7 r- "_' ?7 MICHAEL F. FRISBIE, ESQUIRE E-mail: Michael.frisbie@zurichna.com Attorney I.D. No.: 79096 HENDRZAK & LLOYD 3701 Corporate Center Parkway, Suite 100 Center Valley, Pennsylvania 18034 (610) 709-8705 ADRIENNE RITTER V. DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. ATTORNEY FOR DEFENDANT(S), DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. CUMBERMAND COUNTY COURT OF COMMON PLEAS NO.: 11-3487 Civil TRIAL BY JURY OF 12 DEMANDED DEMAND FOR JURY TRIAL A jury of twelve (12) members, exclusive of alternates, are hereby demanded by Defendants, DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. HENDRZAK & LLOYD Michael F. Frisbie, Esquire Attorney for Defendants MICHAEL F. FRISBIE, ESQUIRE E-mail: Michael.frisbie@zurichna.com Attorney I.D. No.: 79096 HENDRZAK & LLOYD 3701 Corporate Center Parkway, Suite 100 Center Valley, Pennsylvania 18034 (610) 709-8705 RIT ER V. DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. ATTORNEY FOR DEFENDANT(S), DUANE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. CUMBERMAND COUNTY COURT OF COMMON PLEAS NO.: 11-3487 Civil TRIAL BY JURY OF 12 DEMANDED CERTIFICATE OF SERVICE I, MICHAEL F. FRISBIE, ESQUIRE, hereby certify that a true and correct copy of the foregoing Entry of Appearance and Jury Trial Demand were served by first class U.S. Mail, postage prepaid, upon the following on May 10, 2011: James P. Frantz, Esquire Phillip C. Aman, Esquire Frantz Law Group Emerald Plaza 402 West Broadway, Suite 860 San Diego, CA 92101 Richard A. Sadlock, Esquire Angino & Rover 4503 N. Front Street Harrisburg, PA 17110 Ed Hershewe, Esquire The Hershewe Law Firm 431 Virginia Avenue Juplin, MO 64801 HENDRZAK & LLOYD ,Nvq f E!? Michael F. Frisbee, Esquire Attorney for Defendants t s _ ILEO-OFFICE CERTIFICATE ; i H PROT°IJONOTA PREREQUISITE TO SERVICE OF A SUBPOENA JUL 29 PM 12. '33 PURSUANT TO RULE 4009.22 CUMBERLAND COUNTY PENNSYLVANIA IN THE MATTER OF: ADRIENNE RITTER _VS_ RONALD LEIPHART TRUCKING, INC., ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 11-348'7-CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE 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: 07/20/2011 1\ MCS on behalf of / S E J MI H L FRISBIE E Attorney for DEFENDANT JANICE.SANER@ZURICHNA.COM MCS # 89545-LO1 DEll I t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ADRIENNE RITTER -VS- RONALD LEIPHART TRUCKING, INC., ET AL COURT OF COMMON PLEAS TERM, CASE NO: 11-3487-CIVIL 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: JAMES P. FRANTZ, ESQ., PLAINTIFF COUNSEL RICHARD A. SADLOCK, ESQ. MCS on behalf of MICHAEL FRISBIE, 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: 06/28/2011 S on,beha f o IC RISB E, Attorney for DEFENDANT CC: MICHAEL FRISBIE, ESQ. - 284591 JAMES P. FRANTZ, ESQ. FRANTZ LAW GROUP 402 WEST BROADWAY STE 860 SAN DIEGO, CA 92101 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 89545-CO1 DE02 I >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED DR. JAY T. BRIDGEMAN G.E.H.A. PENN STATE HERSHEY SPINE MUTUAL INSURANCE COMPANY DR. ERIC BRADBURN KCI USA DR. MACIEJ T. CHARCZUK DR. JACK MOODY PINNACLE HEALTH REHAB MEDICAL, BILLING, AND X-RAY(S) INSURANCE MEDICAL, BILLING, AND X.-RAY(S) INSURANCE MEDICAL, BILLING, AND X-RAY(S) MEDICAL RECORDS & BILLING MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MCS # 89545-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER vs. RONALD LEIPHART TRUCKING, INC., ET AL File No. 11-3487-CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. JAY T. BRIDGENMAN _ (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 Grog, 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 FRISBIE. ES ADDRESS: 3701 CORPORATE. C'T1; TELEPHONE: _U15) 246-0 SUPREME COURT ID #: ATTORNEY FOR: Defendant rJUV 2 ® 2011 Date: ? -;0-1 f Seal of the Court BY THE COURT: ]? /J D Prothonotary/Clerk, Civil Division Deputy 89545-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JAY T. BRIDGEMAN 30 HOPE DRIVE BLDG B STE 2400 HERSHEY, PA 17033 RE: MCS # 89545-LO1 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Please provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans. EEG's EKG's, EMG's, MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. FILM INVENTORY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 89545-LO1 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ADRIENNE RITTER -VS- RONALD LEIPHART TRUCKING, INC., ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 11-3487-CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS be Yaej?rijke' f /S/ is MI CHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANERQZURICHNA.COM MCS # 89545-L02 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER File No. 11-3487-CIVii. vs. RONALD LEIPHART TRUCKING, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for E H A (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 ATTACTr' urnFR **** - at The MCS Groff Inc 1601 Marrlcet__- Street- Suite 800 Phlladelpbia 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 FRISBIE ES ADDRESS: 3701 CORPORATE CTF TELEPHONE: - SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: la4.et Prothonotary/Clerk, Civil Division t Q L 2 0 20?1J Deputy Date: - ?- ' I I Seal of the Court 89545-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: G.E.H.A, PO BOX 4665 INDEPENDENCE. MO 64051 RE : MCS # 89545 - LO2 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Date of Loss: 06/03/2010 Please provide any and all insurance records and PIP files including but not limited to medical records. Include all claims, correspondence documentation supporting plaintiff's claim, and investigative reports, payments including dates of payments, payee, and reasons for payments. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as otherwise in electronic form. CLAIM #23754346 ho pitals, $100100 for all other providersess of $150.00 for MCS # 89545-L02 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ADRIENNE RITTER TERM, CUMBERLAND -VS- RONALD LEIPHART TRUCKING, INC., ET AL CASE NO: 11-3487-CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS 4ha o /S/ is J ie, + -4o. MICHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANER@ZURICHNA.COM MCS # 89545 - LO3 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER iVIL File No. 11-3487-C vs. RONALD LEIPHART TRUCKING, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PENN ST A TF HERSHEY SPINE - (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 ATT ABED R ER **** - at The MCS Group, Inc_„ 1601 Market Street Suiy_ to 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 FRISBIE ES ADDRESS: 3701 CORPORATE CTF CENTER VALLEY- P A J 8034 TELEPHONE: 246-0200- SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division 'JUL 2 0 2011 (^ I I Deputy Date: b - Seal of the Court 89545-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENN STATE HERSHEY SPINE 30 HOPE DRIVE BLDG B STE 1200 HERSHEY, PA 17033 RE: MCS # 89545-L03 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Please provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EEG's, MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. FILM INVENTORY INCLUDING RECORDS FROM DAVE BLACK Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 89545-L03 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ADRIENNE RITTER TERM, CUMBERLAND -VS- CASE NO: 11-3487-CIVIL RONALD LEIPHART TRUCKING, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS ho /S/ "i.4 1 2)6. MICHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANER@ZURICHNA.COM MCS # 89545-L04 DE11 COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND ADRIENNE RITTER File No. 11-3487-CIVIL _ vs. RONALD LEIPHART TRUCKING, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MUTUAL INSURANCE COMPANY _ (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 00 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 FRISBIE. E ADDRESS: 3701 CORPORATE CT CENTER VALLEY, PA 18034 TELEPHONE: - (215) 246-0900 SUPREME COURT ID #: a ATTORNEY FOR: Defendant JUL 2 0 2011 Date: C Seal of the Court BY THE COURT: [? 1)2 ? . J Prothonotary/Clerk, Civil Division eputy89545-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MUTUAL INSURANCE COMPANY LIBERTY LIFE ASSURANCE CO 100 LIBERTY WAY DOVER, NH 03820 RE: MCS # 89545-L04 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Date of Loss: 06/03/2010 Please provide any and all insurance records and PIP files including but not limited to medical records. Include all claims, correspondence documentation supporting plaintiff's claim, and investigative reports, payments including dates of payments, payee, and reasons for payments. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as otherwise in electronic form. POLICY PP20037659 Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 89545-L04 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ADRIENNE RITTER -VS- RONALD LEIPHART TRUCKING, INC., ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 11-3487-CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS Mehaf yof /S/ ie . 6a. MICHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANER@ZURICHNA.COM MCS # 89545-LO5 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER File No. 11-3487-CIVIL vs. RONALD LEIPHART TRUCKING, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. ERIC 13RADBURN _ (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 FRISBIE ESO ADDRESS: 3701 CORP[)RA71P C:TR PKWY SUITE 100 -CENTER VALLEY, PA 18034 TELEPHONE: (215) 246-090) SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Depu? Date: ?0 D-1 - l I Seal of the Court 89545-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR DR. ERIC BRADBURN 500 UNIVERSITY DRIVE #3100 HERSHEY, PA 17033 RE: MCS # 89545-LO5 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Please provide entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, history and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG's, EMG's, MRI's, and x-rays and all corresponding reports or inventories. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. FILM INVENTORY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 89545-L05 SU10 r CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ADRIENNE RITTER -VS- RONALD LEIPHART TRUCKING, INC., ET AL COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 11-34877-CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS o Abhatof / S / arid ie, 3? MICHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANER@ZURICHNA.COM MCS # 89545-L06 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER File No. 11-3487-CIVIL VS. RONALD LEIPHART TRUCKING, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KCI USA _ (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: 1VIICHAEL FRISBIE ES ADDRESS: 3701 CORPORATE C'TF ut> N l hg VALLEY , PA 18034 TELEPHONE: 215) 246-0900 SUPREME COURT ID #: ? ) _ ATTORNEY FOR: _ Defendant nJUL 2 0 201/1 Date: `? - ?) f Seal of the Court BY THE COURT: AroCivil Division Deputy 89545-06 y EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KCI USA P.O. BOX 659508 SAN ANTONIO, TX 78265 RE: MCS # 89545-LO6 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 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 and prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 89545-L06 SUM • . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ADRIENNE RITTER TERM, CUMBERLAND -VS- RONALD LEIPHART TRUCKING, INC., ET AL CASE NO: 11-3487-CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS eh 1 f o /S/ is ae _ riJke, ?3ck. MICHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANER@ZURICHNA.COM MCS # 89545-L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER VS. RONALD LEIPHART TRUCKING, INC., ET AL File No. _ 11-3487-CIVIL. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. MAC T AR K _ (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 .S 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 FRISBIE E ADDRESS: 3701 CORPORATF rT _t-t 1N ILK VALLEY , PA 18034 TELEPHONE: 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant f nJU 2 0 2011 Date.. "6 - D -7-1 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy 89545-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. MACIEJ T. CHARCZUK 2151 LINGLESTOWN ROAD STE 240 HARRISBURG, PA 17110 RE: MCS # 89545-L07 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Please provide entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, history, physical reports, and all prescriptions records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. is required for fees in excess of $150.00 .00 for all other providers. 1 f CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ADRIENNE RITTER COURT OF COMMON PLEAS 'TERM, CUMBERLAND -VS- RONALD LEIPHART TRUCKING, INC., ET AL CASE NO: 11-3467-CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS tha.11 of /S/ 3c?. MICHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANERCZURICHNA.COM MCS # 89545-L08 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER File No. 11-3487-CIVIL T VS. RONALD LEIPHART TRUCKING, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR JACK MOODY - (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 Strea 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 FRISBIE ESQ. ADDRESS: 3701 CORPORATE CTR. PKWY SUITE 100 CENTER VALLEY. PA 18034 TELEPHONE: 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUL 2 0 2011 f „ ' _ Deputy Date: D ? I , ?,•jJ Sea] of the Court 89545-08 A ,. F EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JACK MOODY 4700 UNION DEPOSIT ROAD #120 HARRISBURG, PA 17111 RE: KS # 89545-L08 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Please provide ent0medical file, to andincluding theuconsultingtadndttreating and all records, c -respondence s h sical physicians. Include rrecords. ihhsndshouldecontain allrecordps in your reports, and all prescriptions possession, all archived records, or records databaselorsothegwiseninuelegtrooiandorm_ items as may be stored in a computer Prior approval is required a e other fees in ersess of $150.00 for hospitals, $100.00 MCS # 89545-L08 SU10 y i CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 COURT OF COMMON PLEAS IN THE MATTER OF: TERM, ADRIENNE RITTER CUMBERLAND CASE NO: 11-:3487-CIVIL -VS- RONALD LEIPHART TRUCKING, INC., ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FRISBIE, 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: 07/20/2011 MCS n be ifjr ?l /S/ is a riSbie,_ . MICHAEL FRISBIE, ESQ. Attorney for DEFENDANT JANICE.SANERQZURICHNA.COM MCS # 89545-L09 DEll t Y F COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ADRIENNE RITTER vs. RONALD LEIPHART TRUCKING, INC., ET AL File No. ?1 _3487-CIVIT SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for P N A HM AT TF; Pt4AR (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: **** SFE ATTAf'irnr? vir?ER at The mrg 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 FRI BIE E ADDRESS: 37 1 C"n12An1D A-,-n TELEPHONE: SUPREME COURT ID ATTORNEY FOR __ Defendant BY THE COU i -- 6L Prothonotary/Clerk, C'vil Division JUL 2 0 2011 ?-- Date: D -? -I I Deputy Sea] of the Court 89545-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH REHAB COMMUNITY GENERAL HOSP 4300 LONDONERRY ROAD HARRISBURG, PA 17109 RE: MCS # 89545-L09 ADRIENNE RITTER 422 WINDING WAY HARRISBURG, PA 17109 Date of Birth: 12-16-1961 Please provide entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, history, physical reports, and all prescriptions records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic: form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 89545-L09 SU10 MICHAEL F. FRISBIE, ESQUIRE E-mail: Michael.frisbie@zurichna.com Attorney I.D. No.: 79096 HENDRZAK & LLOYD 3701 Corporate Center Parkway, Suite 100 Center Valley, Pennsylvania 18034 (610) 709-8705 ATTORNEY FOR DEFENDANT(S), DU NE E. GINGERICH, SR. and RONALD LEIPART TRUCKING, INC. ADRIENNE RITTER CU BERMAND COUNTY C%- COURT OF COMMON PLEAS c+?? rrt V. DUANE E. GINGERICH, SR. and NO : 11-3487 Civil Zp--- N RONALD LEIPART TRUCKING, INC. TRIAL BY JURY OF 12 DEMANZA' ?Q ORDER TO SETTLE, DISCONJINUE AND END Z TO THE PROTHONOTARY: Kindly mark this matter settled, discontinued ANGINO ttorney ended upon payment of costs only. A. And THE HER?HEWE LAW FIRM ED HERS EWE, ESQUIRE And UIRE -fY ?-n ern =m-n 2-,n ?fill w THE FRANTZ LAW GROUP PHILIP A MAN, ESQUIRE