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Home My WebLink About11-3498/r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. F - 2011 Civil Action - (XX) Law () Equity ? rn ? M THELMA STEIDLE RICHARD MCBRIDE t;;F rn 2600 Yale Avenue 4200 Wertzville Road r Camp Hill, PA 17011 Enola PA 17011 CD-1.1 , =Q ®t .! ` DIANE MCBRIDE versus 4200 Wertzville Road Enola, PA 17011 ASHLEY MCBRIDE 4200 Wertzville Road Enola, PA 17011 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. Writ of Summons Shall be issued and forwarded to (XX )Attorney Andrew C. Spears. Esquire 1300 Linglestown Road Harrisburg, PA 17108 (717) 238-2000 Name/Address/Telephone No. of Attorney Signature of Attorney Supreme Court ID No. 87737 Date: C?) 0,09 mPd a Ck * 15349 V_*_ as?S3(a I WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary Date: q -L -,\. 1 Y Deputy ( ) Check here if reverse is used for additional information PROTHON. - 55 c'01 I APR 25 PM 3: 239 CUMBERLAND COUNTY PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 7363 4200 C s Mill Road Harrisburg, PA 17112 717-651-3509 Our File No. 03030-tba CMR Attorney r Defendants Richard and Diane McBride STEIDLE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA VS. No. 3498-2011 RICHARD MCBRIDE, DIANE MCBRIDE : and ASH EY MCBRIDE CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED ENTRY OF APPEARANCE THE PROTHONOTARY: enter the appearance of the undersigned on behalf of Defendants, Richard McBride and Diane McBride in the above captioned case. By: Dated: A ril 21, 2011 MARSHALL DENNEHEY WARNER COLEMAN-&7)GOGGIN Christopher M. Reeser, Esquire Attorney for Defendants Richard and Diane McBride ID# 73672 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 7363 4200 C s Mill Road Harrisbur , PA 17112 717-651-3 09 Our File o. 03030-tba CMR Attorney r Defendants Richard and Diane McBride vs. and STEIDLE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA No. 3498-2011 MCBRIDE, DIANE MCBRIDE : EY MCBRIDE CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, ( hereby Entry of M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do that on April 21, 2011, I served a copy of Defendants Richard and Diane McBride's via First Class United States mail, postage prepaid as follows: Andre C. Spears, Esquire Handle , Henning & Rosenberg 1300 L nglestown Road Harrisburg, PA 17108 Attorn for Plaintiff Ashley McBride 4200 ertzville Road Enola, A 17011 Christopher M. Reeser + OFFICF OFT f-ON0TARY 2011 Tf' 27 PM 12: c; 8 CUMOERL,;tri Cf? Ir T't' ?'-1' YLVA.?lIA Scott D. McCarroll, Esquire Thomas. Thomas & Hafer, LLP I.D. No. 92985 305 N. Front Street, 6th Fir. P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7131 smccarro l l a.tth law. com THELMA STEIDLE, Plaintiff VS. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants Counsel for Defendant Ashley McBride IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3498-2011 CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter our appearance on behalf of Defendant Ashley McBride in the above matter. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP By: D. Mc-Carroll PA I.D. No. 92985 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7131 CERTIFICATE OF SERVICE / / c AND NOW, this (D day o+Haer, , 201 /, I, Coleen M. Polek, of the law firm of Thomas, Thomas P, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Andrew C. Spears, Esq. Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 Coleen M. Polek 934971.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STEIDLE C: -i MCD xrn _ M s• ?:2 =- Vs. Z r r ? NO. 34982011 c n c MCBRIDE, MCBRIDE & MCBRIDE a,% ?° CERTIFICATE v{ c, ? F -- ZC -= = z ° PREREQUISITE TO SERVICE OF A SUBPOENA p'Z o PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 CHRISTOPHER M REESER, 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: 05/23/11 CHRISTOPHER M REESER, ESQUIRE 4200 CRUMS MILL RD SUITE B HARRISBURG, PA 17112 717-651-3500 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3581 By: Victoria Seyler MLR File #: M386837 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STEIDLE Vs. MCBRIDE, MCBRIDE & MCBRIDE I No. 34982011 TO: ANDREW SPEARS, 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: 05/02/11 CHRISTOPHER M REESER, ESQUIRE 4200 CRUMS MILL RD SUITE B HARRISBURG, PA 17112 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 By: Victoria Seyler Enc(s): Copy of subpoena(s) Counsel return card File #: M386837 OF PENNSYLVANIA COUNTY OF -COMBERLAW STEIDLE Vs. File No. 34982011 MCBRIDE, MCBRIDE & MCBRIDE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 CAMP HILL POLICE DEPT, 2199 WALNUT ST, CAMP HILL PA 17011 TO: ATTN: RECORDS CUSTODIAN (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-*-k-? v 1\L Vl?l at MEDICAL LEGAL R INC, 4940 DISSTON ST., . , Pft --- (Address) You may deliver or mail legible copies of the documents or produce things requested b- this subpoena, together with the certificate of caTp1iance, to the party making thi request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving thi subpoena may seek a court orde., crnpe I l i ng you to coup l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS: 4200 CRUMS MILL RD NARRT4B R' PA 17112 TELEPHONE: 2±5 335 32i2 SUPREME COURT ID # ATTORNEY FOR: M386837-01 DEFENDANT S/s DATE: Seal of the Court BY THE 000RT- Prothonotary/Clerk, Civil Division Deputy (Eff. 7/97)- ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, MCBRIDE & MCBRIDE No. 34982011 CUSTODIAN OF RECORDS FOR: CAMP HILL POLICE DEPT POLICE REPORT AND ANY AND ALL NOTES REGARDING A DOG BITE WHICH OCCURRED ON 4/30/09 AT 2608 YALE AVE CAMP HILL PA PERTAINING TO:. NAME: DOG BITE ADDRESS: 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. [ ] 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 or CAMP HILL POLICE DEPT CUMBERLAND M386837-01 * * * SIGN AND RETURN THIS PAGE Scott D. McCarroll, Esquire Thomas, Thomas & Hafer, LLP I.D. No. 92985 305 N. Front Street, 6th Fir. P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7131 smccarrolNa)tthlaw. com THELMA STEIDLE, Plaintiff VS. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants -urn CD I r- = -4 G ? -rt C:) -q n i `?r Counsel for Defendant Ashley McBride IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3498-2011 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a rule upon Plaintiff to file a Complaint in the above matter within 20 days after service of the rule or suffer a judgment of non pros. T THOMAS & HAFER By: ott D. McCarroll, Esq. RULE NOW, Jane o1 , 2011, RULE ISSUED AS ABOVE. Protho otary DAViJ BuUu- By: Deputy MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3509 Our File No. 03030-03184 Attorney for Defendants Richard and Diane McBride THELMA STEIDLE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA VS. No. 3498-2011 RICHARD MCBRIDE, DIANE MCBRIDE : and ASHLEY MCBRIDE CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Thelma Steidle c/o Andrew C. Spears, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be filed against you. MARSHALL DENNEHEY WARNER COLEMG)DGGIN By: ? Christopher M. Reeser, Esquire Attorney for Defendant ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Dated: June 24, 2011 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3509 Our File No. 03030-03184 Attorney for Defendants Richard and Diane McBride THELMA STEIDLE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA vs. No. 3498-2011 RICHARD MCBRIDE, DIANE MCBRIDE : and ASHLEY MCBRIDE CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED DEFENDANTS RICHARD MCBRIDE AND DIANE MCBRIDES' ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT 1. Admitted in part and denied in part. It is admitted that Plaintiff Thelma Steidle currently resides at 2600 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania. The remainder of the allegation in Paragraph 1 is denied as Answering Defendant does not have sufficient information to form a belief as to the truth or falsity of the allegation in Paragraph 1. 2. Admitted in part and denied in part. It is admitted that Defendants Richard and Diane McBride are competent adult individuals currently residing at 4200 Wertzville Road, Enola, 1 J Cumberland County, Pennsylvania. It is denied that Defendant Ashley McBride resides at 4200 Wertzville Road. 3. Admitted. 4. Admitted. 5. Denied. 6. Denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). 6. (Misnumbered). Denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). 7. Denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). 7. (Misnumbered). Denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). COUNT I -NEGLIGENCE Thelma Steidle v. Richard McBride, Diane McBride and Ashley McBride 8. No responsive pleading required. 9. The allegations in Paragraph 9 and subparagraphs 9(a-e) are legal conclusions to which no responsive pleading is required. To the extent that the allegations in Paragraph 9 and subparagraph 9(a-e) are deemed to be factual, those allegations are denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). 10. Denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). 11. Denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). 12. Denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). WHEREFORE, Defendants request judgment be entered in their favor and demand a jury trial. NEW MATTER 13. Plaintiffs' claims or any amendment to those claims may be barred by the applicable statute of limitations. 14. Plaintiffs' claims are barred or limited by the Pennsylvania Comparative Negligence Act, 42 PA.C.S. §7102. 15. Upon information and belief, Plaintiff was a trespasser on the property of Defendants Richard and Diane McBride at all times relevant to the occurrence alleged. 16. Defendants Richard and Diane McBride were not aware of Plaintiffs trespass at any time prior to any incident on April 30, 2009, in which was Plaintiff was bitten by one of Ashley McBride's dogs. 17. Defendants Richard and Diane McBride owed no legal duty to Plaintiff because Plaintiff was trespassing on the McBride's property. 18. Defendant Richard and Diane McBride's property had an electronic fence surrounding its side yard to contain dogs to their property. 19. Upon information and belief, any dog which bit the plaintiff was provoked and therefore Defendants are entitled to judgment as a matter of law. 20. At all time related to the occurrence referenced in Plaintiffs Complaint, Defendant Richard McBride was not at home and was not involved in letting Ashley McBride's dogs out of the house. WHEREFORE, Defendants Richard and Diane McBride request judgment be entered in their favor and demand a jury trial. Respectfully submitted, MARSHALL DENNEHEY WARNER COLE OGGIN By: Christopher M. Reeser, Esquire Attorney for Defendants ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Dated: June 24, 2011 VERIFICATION We, Richard McBride and Diane McBride, do hereby state and aver that we have read the foregoing document which has been drafted by our counsel. The factual statements contained therein are true and correct to the best of our knowledge, information and belief although the language is that of our counsel, and, to the extent that the content of the foregoing document is that of counsel, we have relied upon counsel in making this Verification. This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Richard McBride n I Di CBride DATE: _ _,/, 1-e- e- /, // 0330-03 ] 84/AWNM MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3509 Our File No. 03030-03184 Attorney for Defendants Richard and Diane McBride THELMA STEIDLE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA VS. No. 3498-2011 RICHARD MCBRIDE, DIANE MCBRIDE : and ASHLEY MCBRIDE CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on June 24, 2011, I served a copy of Defendants Richard and Diane McBride's Answer with New Matter via First Class United States mail, postage prepaid as follows: Andrew C. Spears, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Attorney for Plaintiff Scott D. McCarroll, Esquire Thomas Thomas & Hafer, LLP 305 North Front Street PO Box 999 Harrisburg, PA 17108 orney for Defendant Ashley McBride Christopher M. Reeser ?.,, OF I HE ILUI-OFFICE PROTNON OTAR ,r f 2011 JUN 2g AM 10: 13 CUMBERLAND C OUNTY PENNSYLVANIA Scott D. McCarroll, Esquire Thomas, Thomas & Hafer, LLP I.D. No. 92985 305 N. Front Street, 6th Mr. P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7131 smccarrollgtthlaw.com Counsel for Defendant Ashley McBride THELMA STEIDLE, ?N THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 0.3498-2011 CIVIL ACTION - LAW RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants JURY TRIAL DEMANDED NOTICE TO PLEAD You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. DEFENDANT ASHLEY MCBRIDE'S ANSWER WITH NEW MATTER TO THE COMPLAINT And now, comes Ashley McBride, by and through her counsel, Thomas, Thomas & Hafer, LLP, and files this Answer with New Matter to Plaintiff's Complaint and states as follows: 1. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted. Therefore, the averment is denied. 2. Admitted in part and denied in part. It is admitted that Defendants Richard and Diane McBride are adults and currently reside at 4200 Wertzville Road, Enola, Pennsylvania. It is denied that Defendant Ashley McBride resides at 4200 Wertzville Road, Enola, Pennsylvania. It is admitted that Ashley McBride is an adult. The remainder of the averment is a conclusion of law to which no response is required. To the extent any further response is required, the remainder of the averment is denied pursuant to Pennsylvania Rule of Civil Procedure 1029(e). 3. Admitted. 4. Admitted. 5. The averments in this paragraph are denied generally in accordance with Pa. R.C.P. 1029(e). 6. The averments in this paragraph are denied generally in accordance with Pa. R.C.P. 1029(e). 6. [sic] The averments in this paragraph are denied generally in accordance with Pa. R.C.P. 1029(e). 7. The averments in this paragraph are denied generally in accordance with Pa. R.C.P. 1029(e). 8. The averments in this paragraph are denied generally in accordance with Pa. R.C.P. 1029(e). 7.[sic] This paragraph represents a conclusion of law to which not response is required. To the extent that a response is required, the averments in this paragraph are denied generally in accordance with Pa. R.C.P. 1029(e). COUNTI 8. Paragraph 8 represents a paragraph of incorporation to which no response is required. By way of further response, the above paragraphs of the instant Answer with New Matter are incorporated herein as if set forth at length. 2 9. Paragraph 9 and its sub-parts represent conclusions of law to which no response is required. To the extent a response is required, paragraph 9 and its sub-parts are denied generally in accordance with Pa. R.C.P. 1029(e). 10. Paragraph 10 represents a conclusion of law to which no response is required. To the extent a response is required, paragraph 10 is denied generally in accordance with Pa. R.C.P. 1029(e). 11. Paragraph 11 represents a conclusion of law to which no response is required. To the extent a response is required, paragraph 11 is denied generally in accordance with Pa. R.C.P. 1029(e). 12. Paragraph 12 represents a conclusion of law to which no response is required. To the extent a response is required, paragraph 12 is denied generally in accordance with Pa. R.C.P. 1029(e). WHEREFORE, Defendant Ashley McBride requests that this Honorable Court dismiss Plaintiff's Complaint with prejudice. NEW MATTER 13. The above paragraphs of the instant Answer with New Matter are incorporated herein as if set forth at length. 14. Plaintiff's claims may be reduced and/or barred based on the negligence, recklessness, conduct, or omissions of Plaintiff. 15. Plaintiff's claims are barred because Plaintiff was a trespasser at all times relevant. 16. Plaintiff's claims may be barred based on Plaintiff's prior or then occurring provocation, tormenting, abuse, or assault of or on the dog at issue. 3 17. None of the alleged conduct on the part of Answering Defendant amounted to a substantial cause for all and/or some of the Plaintiff s injuries and/or damages. 18. Negligent acts or omissions of other individuals and/or entities may have constituted intervening, superseding causes of the damages and/or injuries alleged to have been sustained by the Plaintiff. 19. Plaintiff may have failed to mitigate her damages. 20. Plaintiff s claims may be barred by the doctrine of waiver. 21. Plaintiff s claims may be barred by the doctrine of accord and satisfaction. 22. Plaintiff s claims may be barred by res judicata or collateral estoppel. 23. Plaintiff fails to state claims upon which relief may be granted. 24. Plaintiffs claims may be barred by the applicable statute of limitations or other procedural limitations periods. 25. Plaintiff s claims may be barred by prior enforceable agreement to settle. WHEREFORE, Defendant Ashley McBride requests that this Honorable Court dismiss Plaintiff s Complaint with prejudice. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Date: z 7 ?? colt D. McCarroll, Esquire Attorney I.D. No. 92985 P.O. Box 999 305 N. Front Street Harrisburg, PA 17108-0999 (717)237-7131 Attorneys for Defendant Ashley McBride 4 VERIFICATION I, Ashley McBride, have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, information and belief. This Verification and statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities, I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S. § 4904. Ashley McBri e Date: Ce IZZI l CERTIFICATE OF SERVICE AND NOW, this day of , 201 /, I, Coleen M. Polek, of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Andrew C. Spears, Esq. Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 Cole-en M. Polek IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY C? zj" - M STEIDLE im ti Wr- Vs. -<> ?., -0 i? NO. 34982011 <C3 MCBRIDE, ET AL • ?= CERTIFICATE M ?; C 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 CHRISTOPHER M REESER, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 06/20/11 Y" V" CHRISTOPHER M REESER, ESQUIRE 4200 CRUMS MILL RD SUITE B HARRISBURG, PA 17112 717-651-3500 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3336 By: Ruby Schwartzberg MLR File #: M387888 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STEIDLE Vs. MCBRIDE, ET AL I No. 34982011 TO: ANDREW SPEARS, ESQ (PLAINTIFF) SCOTT MCCARROLL 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: 05/27/11 CHRISTOPHER M REESER, ESQUIRE 4200 CRUMS MILL RD SUITE B HARRISBURG, PA 17112 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO; MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Ruby Schwartzberg Enc(s): Copy of subpoena(s) Counsel return card File #: X387888 STEIDLE Vs. MCBRIDE, ET AL File No. 34982011 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: CUMBERLAND FAMILY PRACT, 4470 VALLEY RD, ENOLA PA 17025 (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-*k4m nrTAit 1\L Vl*l at REPRODUCTIONS, MEDICAL LEGA INCA . , . , -- --- (Address) You may deliver or mail legible copies of the documents or produce things requested tthis subpoena, together wit!) the certificate of reap 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.onablr 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 cxnpe l l i ng you to ca, l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAPE: CHRISTOPHER M REESER, ESQ ADORESS: 4200 CRUMS MILL RD HARRTSB R , PA 17112 TELEPHONE: 335- 324:2 SUPREME OOURT ID # __ _ ATTORNEY FOR: 73 DEFENDANT M387888-01 DATE: S 31 -t! Sea! of the COMMONWEALTH OF PENNSYLVANIA CO.l[ai'Y OF BY THE Prot 11tary/C1 k, Civil Division Deputy (Eff. -1/97) ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR: CU54BERLAND FAMILY PRACT ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ l 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. [ l 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 or CUMBERLAND FAMILY PRACT CUMBERLAND M387888-01 * * * SIGN AND RETURN THIS PAGE ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills COMMONWEALTH OF PENNSYLVANIA COi.I M OF -CUMBERLAND STEIDLE Vs. MCBRIDE, ET AL File No. 34982011 ORIGINAL X-RAYS REQUESTED. MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: FIRST CHOICE REHAHB SPEC, 4033 LINGLESTOWN RD, HARRISBURG PA 17112 (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 orST9 ADDENDUM - -- at MEDICAL LEGAL REPRODUCTIONS 494-0 DISSTON ST., FRILW. --- (Address) You may deliver or mail legible copies of the documents or produce things requested h? this subpoena, together wit!, the certificate of carp 1 i ance , to the party making th i request at the address listed above. You have the right to seek in advance the rea.onablc- cost of preoaring 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, subpoena may seek a court orde:- rxxrpe I l i ng you to carp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS: 4200 CRUMS MILL RD HARR T RRTTRC A 17112 TELFPHONE: SUPREME OOURT ID # _ ATTORNEY FOR : 7 3 6 3 2 DEFENDANT M387888-02 DATE : __' Jf --r Seal of the Court BY THE COURT: Prothonotary C1erl, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR: FIRST CHOICE REHAHB SPEC ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ J 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. [ l 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 or FIRST CHOICE REHAHB SPEC CUMBERLAND M387888-02 * * ?` SIGN AND RETURN THIS PAGE ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills COMM3NWEALTH OF PENNSYLVANIA COURN OF -CUMBERLAND STEIDLE Vs. File No. 34982011 MCBRIDE, ET AL ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCXPIENTS pRD HCALBILLING REQUESTED FOR DISCOVERY PURSUANT TO RULE 4009.22 HERITAGE DIAG CTR, 3 WALNUT ST STE 100, LEMOYNE PA 17043 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 g at - _._.__ MEDICAL LEGAL REPRODUCTIONS C, 4941-6 DISSTON ., PHILA. PA-- --- (A ress ) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together wit!) the certificate of compliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rearonablr 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 ordef• rxxmpe i l i ng you to carp l y with it'.. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS: 4200 CRUMS MILL RD A 17112 TELEPHONE: SUPREME COURT ID # - ATTORNEY FOR: M387888-03 73632 DEFENDANT DATE : Seal of the Court BY THE COURT : Prot / erk, r Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR : HERITAGE DIAG CTR ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ) RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS 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 or HERITAGE DIAG CTR CUMBERLAND M387888-03 * * * SIGN AND RETURN THIS PAGE ADDENDUM TO SUBPOENA Any and all medical records, including, but not Ilmitarl to, inpatient records outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills COMMDNWEALTH OF PENNSYLVANIA COIRMY OF -CUMBERLAND STEIDLE Vs. Fi le No. MCBRIDE, ET AL 34982011 MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL PA 17011 TO: ATTN: MEDICAL RECORDS DEPT (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 orstbir?g? L?L' 1\""_N'` LJ? at MEDICAL LEGAL REPROD INC, 49 .5T., PHILIt-. , P2k --- (Address) You may deliver or mail legible copies of the documents or produce things requester' ty this subpoena, together wit!-I the certificate of canpliance, to the party making this request at the address listed above. You have the right to seek in advance the rea7,onablc- cost of preoaring 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- subpoena may seek a court orde, Lrmpe l l i ng you to carp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS: 4200 CRUMS MILL RD uARRTSRTTR(;, PA 17112 TELEPHONE: SUPREME COURT ID ATTORNEY FOR: M387888-04 73632 DEFENDANT DATE : - Seal of the Court BY THE COURT: Prot ary/Cl , Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSP ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. 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 or HOLY SPIRIT HOSP CUMBERLAND M387888-04 * * * SIGN AND RETURN THIS PAGE * * * ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STEIDLE Vs. MCBRIDE, ET AL File No. 34982011 ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL PA 17011 TO: ATTN: RADIOLOGY DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court tc produce the following documents orSlgS: ?L f? ADDENDUM at MEDICAL LEGAL REPRODUCTIONS INC, 494U VISSTUR ST., . (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together wit!) the certificate of ccnp 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 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:- crmpe l l i ng you to ca, l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS : 4200 CRUMS MILL RD jRTCRTTR(",_?A 17112 TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: 73632 DEFENDANT M387888-05 DATE : Seal of the Court BY THE COURT: -X)& Prothono /Clerk, vil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. No. 34982011 MCBRIDE, ET AL CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSP ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXYXB996 ORIGINAL X-RAYS REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. 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 or HOLY SPIRIT HOSP CUMBERLAND M387888-05 * * * SIGN AND RETURN THIS PAGE ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills rr*WV W'ALTH OF PENNSYLVANIA ax)N1i'Y OF CUMBERLAND STEIDLE Vs. MCBRIDE, ET AL File No. 34982011 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 DR JAMES NORTON, 3812 MARKET ST, CAMP HILL PA 17011 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-tliin at MEDICAL LEGAL REPRODUCTIONS IXiC, 4940 DISSTON ST. , PHIL-K. F? (Address) You may deliver or mail legible copies of the documents or produce things requester! 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,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 thii subpoena may seek a court ordei" cAxnpe i l i ng you to carp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ . ADDRESS: 4200 CRUMS MILL RD HARRISBURG PA 17112 TELEPHONE: SUPREhE COURT ID # _ ATTORNEY FOR: 73632 DEFENDANT M387888-06 DATE : J I Seal of the Court BY THE OOJRT: Prot ar Cler , Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. No. 34982011 MCBRIDE, ET AL CUSTODIAN OF RECORDS FOR: DR JAMES NORTON ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS 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 or DR JAMES NORTON CUMBERLAND M387888-06 * * * SIGN AND RETURN THIS PAGE * * * ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills STEIDLE Vs. MCBRIDE, ET AL COK40NWFALTH OF PENNSYLVANIA COUNTY OF a MU" Fi le No. 34982011 ORIGINAL X-RAYS REQUESTED TO: MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE Doaj-ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 ORTHO INST OF PENNA, 3399 TRINDLE RD, CAMP HILL PA 17011 (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 °"S 'g T?$--ADDi NT1E . L -- T TA d MEDICAL LEGAL REPRODUCTIONS IAC, 49ST., . , PA --- (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 rea.onablE cost of preoaring 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> subpoena may seek a court order. compelling you to coup l y with it. THIS SUBPOENA WAS ISSUED AT THE REGMST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS : 4200 CRUMS MILL RD NARRT4RTTR(", PA 17112 TELEPHONE: SUPREME COURT ID ATTORNEY FOR: 73632 DEFENDANT M387888-07 BY THE COURT: DATE : S-31-11 Seal of the court lerk, ivil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR: ORTHO INST OF PENNA ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ J 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 or ORTHO INST OF PENNA CUMBERLAND M387888-07 * * * SIGN AND RETURN THIS PAGE * * * ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRis, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills COM143NWEALTH OF PENNSYLVANIA 0OEJNrY OF-CUMBERLAND STEIDLE Vs. MCBRIDE, ET AL File No. 34982011 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCIIMIENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENNA NEUROLOGICAL ASSOCS, 110 LOWTHER ST, LEMOYNE PA 17043 (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? at MEDICAL LEGAL REPRODUCTIONS ,INC, 4940 DISSTON ST., . , F,F-- `- (Aaar"ess ) You may deliver or mail legible copies of the documents or produce things requested t? this subpoena, together with the certificate of ccrTpliance, 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 orde,- c=peIling you to camply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS: 4200 CRUMS MILL RD unRRZSALIRC, pA 17112 TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: M387888-08 DATE: cJ - w 73632 DEFENDANT Seal of the Court BY THE COURT U Prot tary/Clerk, ivil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR : PENNA NEUROLOGICAL ASSOCS ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS 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 ( ) X-RAYS Date CUMBERLAND M387888-08 ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Authorized signature or PENNA NEUROLOGICAL ASSOCS * * * SIGN AND RETURN THIS PAGE * * * ADDENDUM TO SUBPOENA Any and all medical records, including, hi it not limited to, inpatient records, outpatient record,, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills OF PENNSYLVANIA COUNTY OF CUMBERLAND Vs. STEIDLE MCBRIDE, ET AL File No. 34982011 MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUIENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 PINNACLE HEALTH SYSTEM, PO BOX 8700, HARRISBURG PA 17105 TO: ATTN: MEDICAL RECORDS DEPT (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 orSthOTffl at MEDICAL LEGAL RODUCTIONS INC, 49ST., . , Pte--- (Address) You may deliver or mail legible copies of the documents or produce things requested t) this subpoena, together with the certificate of caTpliance, to the party making thi_ request at the address listed above. You have the right to seek in advance she rea.onable cost of preoaring 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 thi3 subpoena may seek a court orde;- cx0npe I l i ng you to camp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M "REESEE",;"ESQ K; 4r g`R ESQ ADDRESS: - 209 CRTTMQ MTT.TR1). HARRISBURG PA 171 1 2, , TELEPHONE: 21 5-335-321 2 SUPREME COURT I D# 7 3 6 3 2 ATTORNEY FOR : DEFENDANT M387888-09 DATE: 5 - ?:- -'/ ( Seal of the Court BY TFE COURT Prot /Clerk, Civil Division Deputy (Eff. 7/97) ADDEND UM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH SYSTEM ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. 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 ( ) X-RAYS ate CUMBERLAND M387888-09 ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Authorized signature or PINNACLE HEALTH SYSTEM * * * SIGN AND RETURN THIS PAGE * * * ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills STEIDLE Vs. MCBRIDE, ET AL ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCLWNTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PINNACLE HEALTH SYSTEM, PO BOX 8700, HARRISBURG PA 17105 TO: ATTN: RADIOLOGY DEPT (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"gg:,T, - _ F i?rr?r n, ,r at ? _.._ MEDICAL LEGAL REPRODUCTIONS INC, 4940 ST., PKILA. , -- --- (Address) You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of canpliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the rea7,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 thii subpoena may seek a court orde cxnpe l l i ng you to crap l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME, CHRISTOPHER M REESER, ESQ ADDRESS: 4200 CRUMS MILL RD HARR T SRTTRC; PA 17112 TELEPHONE: SUPREhE COURT ID r ATTORNEY FOR: 73632 DEFENDANT M387888-10 DATE : -5-0/-// seal of the court BY THE COURT : Prot y/Clerk, Ci i l Division Deputy COMMONS ENLTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 34982011 (Eff. T/97) ADDENDUM STEIDLE Vs. MCBRIDE, ET AL TO SUBPOENA No. 34982011 CUSTODIAN OF RECORDS FOR : PINNACLE HEALTH SYSTEM ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ l 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 Aut orize signature or PINNACLE HEALTH SYSTEM CUMBERLAND M387888-10 * * * SIGN AND RETURN THIS PAGE ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRIs, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills COMMONWEAILTH OF PENNSYLVANIA COUNTY OF -CUMBERLAND STEIDLE Vs. MCBRIDE, ET AL Fi le No. 34982011 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: VASCULAR ASSOCS, 800 POPLAR CHURCH RD, CAMP HILL PA 17011 (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 EE g aDi rw ,r `l?I - --- at FA -- --- MEDICAL LEGAL REPRODUCTIONS 4940 DISSTON ., PHTLX_., (Address) You may deliver or mail legible copies of the documents or produce things requested ti? this subpoena, together with the certificate of ccmpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea,onablc_ cost of preoaring the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twenty (20) days after its service, the party serving thi; subpoena may seek a court orde-- rxn pe l l i ng you to coup l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ . ADDRESS : 4200 CRUMS MILL RD RRTCRTTRf A 17112 TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: M387888-11 73632 DEFENDANT DATE: Seal of the Oourt BY THE COURT: Prothom y/Clerk, vi l Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. MCBRIDE, ET AL No. 34982011 CUSTODIAN OF RECORDS FOR: VASCULAR ASSOCS ***SEE ATTACHED ADDENDUM*** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/66 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS 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 or VASCULAR ASSOCS CUMBERLAND M387888-11 * * * SIGN AND RETURN THIS PAGE ADDENDUM TO SUBPOENA Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, x-ray films, MRls, CT scans, or other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STEIDLE Vs. MCBRIDE, ET AL NO. 34982011 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 F ?5 -C rq Ci r V 1 - ° 'CIO -; c) v ? As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 CHRISTOPHER M REESER, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 08/16/11 CHRISTOPHER M REESER, ESQUIRE 4200 CRUMS MILL RD SUITE B HARRISBURG, PA 17112 717-651-3500 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3336 By: Ruby Schwartzberg MLR File #: M389982 pp lT.q'R OF PFNNMVANIA CDOI+Tl'Y OF CLI 3EEMAND STEIDLE Vs. MCBRIDE, ET AL File No. 34982011 MEDICAL BILLING REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 HERSHEY MED CTR, 500 UNIVERSITY DR BOX 850, HERSHEY PA 17033 TO: ATTN: MEDICAL RECORDS DEPT - (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 bg at _ MEDICAL LEGAL REPRODUCTIONS INC, 4940 VIbST0N ST., PHIJUA.1 PA (Address) You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of carpliance, to the party making thi request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or 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 thii subpoena may seek a court orde., cortpe l l i ng you to carp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REOLEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS: 4200 CRUMS MILL RD HARRISBURG, PA 17112 TELEPHONE: SUPREME COURT ID # _ 73632 ATTORNEY FOR: DEFENDANT M389982-01 DATE: I _a /- 1 eat of the Court BY THE T: &'f/ r t y/ 1erk, Civil Division Deputy (Eff. 7/9T) ADDENDUM A STEIDLE Vs. MCBRIDE, ET AL TO SUBPOENA No. 34982011 CUSTODIAN OF RECORDS FOR: HERSHEY MED CTR **SEE ATTACHED ADDENDUM** PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/06 SSAN: XXXXX8996 MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. 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 X-RAYS to CUMBERLAND M389982-01 ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Authorized signature or HERSHEY MED CTR * * * SIGN AND RETURN THIS PAGE * * * A HERSHEY MED CTR. ADDENDUM Any and all medical records, including, but not limited to, inpatient records, outpatient records, physical therapy records, rehab records, lab reports, other diagnostic testing performed, together with all medical reports, diagnostic reports, notes, memoranda, correspondence and medical bills. p LTH OF PENNSYLVANIA QOUNrY OF -CUMBERIAM STEIDLE Vs. File No. 34982011 MCBRIDE, ET AL ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMEWTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 HERSHEY MED CTR, 500 UNIVERSITY DR BOX 850, HERSHEY PA 17033 TO: ATTN: RADIOLOGY DEPT (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 orSVk9X ENcDu ,? L A at MEDICAL LEGAL REPRODUCTIONS I ., ., P1?---- (Address) You may deliver or mail legible copies of the documents or produce things requested t? this subpoena, together with the certificate of cc pliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving thia subpoena may seek a court orde.- cxmpe l ling you to carte l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER M REESER, ESQ ADDRESS : 4200 CRUMS MILL RD HARRISBURG PA 17112 TELEPHONE: 2±5-335 3212 SUPREME OOURT ID # ATTORNEY FOR: 73 632 DEFENDANT M389982-02 DATE : Sea] of the Court BY T: <??ot 7 /Clerk, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA STEIDLE Vs. No. 34982011 MCBRIDE, ET AL CUSTODIAN OF RECORDS FOR : HERSHEY MED CTR ALL X-RAY FILMS, MRIS, CT SCANS OR OTHER DIAGNOSTIC TESTING PERFORMED ALONG WITH ALL DIAGNOSTIC REPORTS. PERTAINING TO: NAME: THELMA STEIDLE ADDRESS: DATE OF BIRTH: 10/21/06 SSAN: XXXXX8996 ORIGINAL X-RAYS REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ l 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 or HERSHEY MED CTR CUMBERLAND M389982-02 * * * SIGN AND RETURN THIS PAGE Scott D. McCarroll, Esquire Thomas, Thomas & Hafer, LLP I.D. No. 92985 305 N. Front Street, 6th Flr. P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7131 smccarrol l @tthl aw. com THELMA STEIDLE, Plaintiff ?-???G-O>: FICr. ? f.> PROTHONOTARY 2012 JAN 2 S W 11: 4 Pi CUMBERLAND COUNTY PENNSYLVANIA Counsel for Defendant Ashley McBride THE COURT OF COMMON PLEAS MBERLAND COUNTY, PENNSYLVANIA VS. 0.3498-2011 CIVIL ACTION - LAW RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO ISSUANCE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party; 2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to this Certificate; 3. No objections to the subpoena issued have been made; and 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoenas. THOMAS, THOMAS & HAFER, LLP Date: January 2? , 2012 By: S;;"colt D. McCarroll, Esq. Attorney for Defendant THELMA STEIDLE, Plaintiff vs. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA NO. 3498-2011 CIVIL ACTION - LAVb' JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 To: Andrew C. Spears, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg. PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 Defendant intends to serve a subpoena identical to the one 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. THOMAS, THOMAS & HAFER, LLP Date By-_ ott D. McCarron Esquire Thomas, Thomas & Hafer. LLP I.D. No. 92985 305 N. Front Street. 6th Flr. P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7131 02954' Scott D. McCar-oll. Esquire Thomas. Thomas &- Hafer. LLP I.D. No. 92985 305 N. Front Street. 6th Fir. P.O. Box 999 Harrisbur PF_ 17108-0999 (717) 237-7131 cmcnnrrnll(utthlaw.Com Counsel for Defendant Ashley McBride THELMA STEIDLE, Plaintiff VS. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3498-2011 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of Pennsylvania, 3399 Trindle Road, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copy of all medical records pertaining to Thelma Steidle, DOB: 10/21/1966• Social Securiri, No.: 171-56-8996, including but not limited to: medical records, evaluations. consultation reports. nursing notes. therapy notes, progress notes, records of other health care providers reports of diamostic studies correspondence and bills from 4/30/99 to the present to: Thomas. Thomas R. Hafer, LLP. 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: SUPREME COURT ID# ATTORNEY FOR: BY THE COURT: DATE: 10294-'(, Scott I). McCarroll, Esquire P.O. Box 999, Harrisburg, PA 17108-0999 (717) 237-7131 92985 Defendants Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE 1. Deborah A. Tammy.. a Paralegal for the law firm Thomas, Thomas & Hafer. LLP.. hereby state that a true and correct copy of the attached document(s) was served upon all counsel of record b? first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Andrew C. Spears, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 THOMAS, THOMAS & HAFER, LLP Date: December- 2011 By: Deborah A. Tammy, Paralegal 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Phone: (717) 237-7100 Fax: (717) 237-7105 l Oz9?i- 10 CERTIFICATE OF SERVICE I, Deborah A. Tamny, a Paralegal for the law firm Thomas, Thomas & Hafer, LLP, hereby state that a true and correct copy of the attached document(s) was served upon all counsel of record by first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Andrew C. Spears, Esq., Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esq. Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mills Road, Suite B Harrisburg, Pa 17112 Date: Z , 2012 THOMAS, THOMAS & HAFER, LLP 7 77W-?'? Deborah A. Tamny, Para al 1040907.1 w Scott D.McCanoll,Esquire_ O THE PROTHONOTA RY Thomas,Thomas&Hafer,LLP 2�t 3 J UL 19 Pli Z: 12 I.D.No.92985 ! 305 N.Front Street,6th Fir. P.O.Box 999 CUMBERLAND COUNTY. Harrisburg,PA 17108-0999 PENNSYLVA141A (717)237-7131 smccarroll @tthlaw.com Counsel for Defendant Ashley McBride THELMA STEIDLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 3498-2011 CIVIL ACTION—LAW RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants RY TRIAL DEMANDED DEFENDANT ASHLEY MCBRIDE'S MOTION TO COMPEL PLAINTIFF'S DISCOVERY RESPONSES AND NOW comes Defendant Ashley McBride, by and through her counsel, Thomas, Thomas & Hafer, LLP, and respectfully files the instant Motion to Compel Plaintiff s Discovery Responses, stating and averring as follows: 1. Generally speaking, this matter arises out of a dog bite alleged to have occurred on or about April.30, 2009, wherein Plaintiff claims injuries as a result of Moving Defendant's dog biting her on her right thigh. 2. Plaintiff s deposition was originally noticed for January 23, 2013, via a Notice of Deposition served on October 1, 2012. 3. That deposition was cancelled at the 11th hour due to Plaintiff s counsel's emergency. 4. Plaintiffs deposition was re-scheduled to occur on May 9, 2013, via a Notice served on February 20, 2013. 5. At that time, Plaintiff did not appear for her deposition, and her counsel represented that she was not going to appear for the deposition due to a death in the family. 6. Plaintiffs deposition is currently scheduled for July 31, 2013. 7. On or about May 10, 2013, Moving Defendant served Plaintiff with Supplemental Interrogatories and Requests for Production of Documents. A copy of the Supplemental Interrogatories and Requests for Production of Documents are attached hereto collectively with the cover letter accompanying same as Exhibit A. 8. This supplemental discovery concerns, among other things, verifying Plaintiffs excuse,provided through counsel, for not attending her deposition. 9. Having received no response, the undersigned wrote to Plaintiff's counsel inquiring as to the status of the discovery responses on or about July 10, 2013. A copy of that correspondence is attached hereto as Exhibit B. 10. In that correspondence, the undersigned j advised that if no responses were received by July 15, 2013, a Motion to Compel would be filed, and the costs incurred in the preparing the same would be sought. Ex. B. 11. In said correspondence, the undersigned advised that Plaintiff's responses to the outstanding discovery were needed prior to that date. Ex. B. 12. To date, no responses, objections, or requests. for an extension of time to respond have been made by Plaintiff. 13. This failure to respond to the discovery makes it likely that Plaintiffs deposition will not go forward, and will have to be reset, for a fourth time. 1 14: Pursuant to Pa.R.C.P. Nos. 4006 and 4009.12, Plaintiff is required to serve answers or objections to Moving' Defendant's Supplemental Interrogatories and Requests for Production of Documents within thirty days of service. 15. Moving Defendant is entitled to Plaintiff's discovery responses' pursuant to Pennsylvania Rules of Civil Procedure governing discovery. 16. As previously stated, Plaintiff has served absolutely no response —or objections - whatsoever to Moving Defendant's supplemental discovery iquests. 17. " Moving Defendant has been prejudiced by Plaintiff's continued refusal to provide discovery responses as she has been precluded from obtaining investigative materials to further the course of the instant litigation, and to prepare her defense to Plaintiff s'claims, and to prepare for Plaintiff's deposition. 18. Pennsylvania Rule of Civil Procedure 4,019 permits this Honorable Court to enter an Order requiring that Plaintiff provide full and complete responses to Moving Defendant's supplemental discovery requests, or to allow such other sanctions, including but not limited to the preclusion of evidence at trial,upon further application made to this Honorable Court. 19. Pursuant to Local Rule 208.2(4), concurrence was sought from counsel in the instant Motion. Counsel have not responded to the request. WHEREFORE, Defendant Ashley McBride respectfully requests this Honorable Court grant her Motion to Compel, and issue an Order in the form proposed. Respectfully submitted, THOMAS OMAS &HAFER,LLP Date: ��($�) Scott Carroll, Esquire xro y I.D. No. 92985 1320381.1 orneys for Defendant Ashley McBride nn r H THOMAS, THOMAS & HAFERLLP Street Address: Attorneys At Law 305 North Front Street,Harrisburg,PA 17101 Mailing Address: P.O.Box 999,Harrisburg,PA 17108 Phone: 717.237.7100 'Fax: 717.237.7105 Scott A McCarroll (717)237-7131 smccarroll @tthlaw.corn May 10, 2013 Andrew C. Spears, Esq. Handler, Henning&Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Re: Steidle v. McBride Our File: 348-10798 Dear Mr. Spears: Enclosed please find Supplemental Interrogatories and Request for Production of Documents addressed to Plaintiff in the above-referenced matter. Pursuant to the applicable Pennsylvania Rules of Civil Procedure, I look forward to Plaintiff's timely response thereto prior to the depositions which are scheduled for July 31,2013. Very truly yours, THOM THOMAS & HAFER,LLP ott D. McCarroll dat991586.21 cc: Christopher M. Reeser,Esquire(w/enc.) EXHIBIT Harrisburg Bethlehem Pittsburgh Philadelphia Wilkes-Barre Baltimore, MD Scott D. McCarroll,Esquire Thomas,Thomas&Hafer, LLP I.D.No. 92985 305 N. Front Street,6th Flr. P.O.,Box 999 Harrisburg, PA 17108-0999 (717)237-7131 smccarroll@tthlaw.com Counsel for Defendant Ashley McBride THELMA STEIDLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. 0.3498-2011 CIVIL ACTION—LAW RICHARD MCBRIDE,DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants JURY TRIAL DEMANDED SUPPLEMENTAL INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT ASHLEY MCBRIDE DIRECTED TO PLAINTIFF,THELMA STEIDLE To: Plaintiff,Thelma Steidle c/o Andrew C. Spears,Esquire Pursuant to Pa.R.C.P. 4005, Defendant serves the within interrogatories on Plaintiff, and make demand on Plaintiff to answer the same under oath, within thirty (30) days. The answers to these interrogatories shall be inserted in the spaces provided following the interrogatories. If there is insufficient space to answer an interrogatory,the remainder of the answer shall follow on a supplemental sheet. These interrogatories are deemed to be continuing in nature, in accordance with the provisions of the Pennsylvania Rules of Civil Procedure, as amended. If between the time of forwarding your original answers to these interrogatories and the time of trial in this matter, you or anyone acting on your behalf learns the identity and location of additional persons having knowledge of discoverable facts and the identity of a person or persons expected to be called as an expert witness, a witness at trial not disclosed in your answers, or responses to the interrogatories, pursuant to Pa.R.C.P. 4007.4, you are required to supplement your response through supplemental answers to the interrogatories. DEFINITIONS "Document" means any written, printed, typed, or other graphic matter of any kind or nature, however produced or reproduced, including photographs, microfilms,phonographs, video and audio tapes, punch cards, magnetic tapes, discs, data cells, drums, and other data compilations from which information can be obtained. "Identify" or "Identity" means when used in reference to— (1) A natural person, his or her: (a) full name; and (b) present or last known residence and employment address (including street name and number, city or town, and state or country); (2) A document: (a) its description(e.g., letter, memorandum, report, etc.), title, and date; (b) its subject matter; (c) its author's identity; (d) its addressee's identity; (e) its present location; and (f) its custodian's identity; (3) An oral communication: (a) its date; (b) the place where it occurred; (c) its substance; (d) the identity of the person who made the communication; (e) the identify of each person to whom such communication was made; and (f) the identity of each person who was present when such communication was made; (4) A corporate entity: (a) its full corporate name; (b) its date and place of incorporation, if known; and (c) its present address and telephone number; (5) Any other context: a description with sufficient particularity that the thing may thereafter be specified and recognized, including relevant dates and places, and the identification of relevant people, entities, and documents. "Incident" means the occurrence that forms the basis of a cause of action or claim for relief set forth in the complaint or similar pleading. 2 "Person" means a natural person, partnership, association, corporation, or government agency. STANDARD INSTRUCTIONS (1) Duty to answer. --The interrogatories are to be answered in writing,verified, and served upon the undersigned within 30 days of their service on you. Objections must be signed by the attorney making them. In your answers, you must furnish such information as is available to you, your employees, representatives, agents, and attorneys. Your answers must be supplemented and amended as required by the Pennsylvania Rules of Civil Procedure. (2) Claim of privilege. -- With respect to any claim of privilege or immunity from discovery, you must identify the privilege or immunity asserted and provide sufficient information to substantiate the claim. (3) Option to produce documents. -- In lieu of identifying documents in response to these interrogatories, you may provide copies of such documents with appropriate references to the corresponding interrogatories. SUPPLEMENTL INTERROGATORIES 1. As to all bills for medical treatment or examination because of injuries you suffered as a result of the incident on April 30,2009,please provide: (a) The identity and address of all medical providers; (b) The dates on which each such treatment or examination was rendered, and the charge for each; (c) The name and address of all individuals or entities making payment on any incident related bills; (d) A listing of all unpaid bills; and (e) Whether any liens has been asserted for the amount of medical bills or benefits paid, and if so,the date you received notice of the lien and the amount of the lien. ANS'VMR: 3 2. If you have received medical treatment or examination (including x-rays) because of injury or disease you suffered as a result of the incident since your answers to discovery received in January 2012, state: (a) The identity of each hospital at which you were treated or examined; (b) The date on which each such treatment or examination at a hospital was rendered, and the charge by the hospital for each; (c) The identity of each doctor or practitioner by whom you were treated or examined; and (d) The date on which each such treatment or examination by a doctor or practitioner was rendered, and the charge for each. ANSWER: 3. When, where and by whom were you last examined or treated for any condition alleged to have resulted from the incident? If still under treatment, state the nature and frequency. ANSWER: 4 4. Please state what prevented you from attending your deposition scheduled for May 9, 2013. ANSWER: 5. Please state if you prepared for your deposition which was scheduled to be taken on May 9, 2013. If your answer is in the affirmative,please state the following: (a) The name of each individual(s) you met with to prepare for the deposition; (b) The date(s) you met which each individual to prepare for the deposition; and (c) Identify all documents reviewed in preparation for the deposition. ANSWER: 5 6. Please provide the names and dates of death of all family members (including blood relation, in-laws and extended family) within six months of May 9, 2013. ANSWER: 7. Please identify the name of the individual whose death prevented you from attending the deposition on May 9,2013. ANSWER: 6 SUPPLEMENTAL REQUEST FOR PRODUCTION OF DOCUMENTS 1. Copies of any and all documents that contain any of the information requested in the interrogatories above. RESPONSE: 2. Copies of any and all medical records and bills since your answers to discovery received in January 2012. RESPONSE: 3. Copies of any and all obituaries that contain any of the information requested in Interrogatory 7 above. RESPONSE: Respectfully submitted, THOMAS,THOMAS & HAFER,LLP Date: May d, 2013 By: cott D. McCarroll PA I.D. No. 92985 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7131 (717) 237-7105 fax smecarroll@tthlaw.com 7 CERTIFICATE OF SERVICE AND NOW, this fi day of May, 2013, I, Deborah A. Tamny, of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Andrew C. Spears, Esquire Handler, Henning&Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman& Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 Deborah A. Tamny 1286701.1 8 rrTHOMAS, THOMAS & HAFERLLP Street Address: Attorneys At Law 305 North Front Street,Harrisburg,PA 17101 Mailing Address: P.O.Box 999,Harrisburg,PA 17108 Phone: 717.237.7100 Fax: 717.237.7105 Scott D.McCarroll (717)237-7131 smccarroll@tthlaw.com July 10, 2013 FAX 717 233-3029 Andrew C. Spears, Esquire Handler, Henning&Rosenberg 1300 Linglestown Road Harrisburg,PA 17108 Re: Steidle Y. McBride Our File: 348-10798 Dear Mr. Spears: Please be advised that Supplemental Interrogatories and Request for Production of Documents were served upon Plaintiff on May 10, 2013. To date, we have not had the courtesy of a reply. As you are aware, Plaintiff s depositions are scheduled for July 31, 2013, and I must have Plaintiff's responses to the supplemental discovery prior to that date. If I do not receive discovery responses by July 15, 2013, I will file a Motion to Compel with costs sought related to the same. Thank you for your attention to this matter. Very truly yours, THO HOMAS & HAFER,LLP ott D. McCarroll dat991586.22 cc: Christopher M. Reeser, Esquire (w/enc.) EXHIBIT Harrisburg Bethlehem Pittsburgh Philadelphia Wilkes-Barre Baltimore, MD _ www.tthiaw.com i CERTIFICATE OF SERVICE I, Corey J. Adamson, for the law firm Thomas, Thomas &Hafer, LLP, hereby state that a true and correct copy of the attached document(s)was served upon all counsel of record by first class United States mail, postage prepaid,.addressed as follows,.on the date set forth below: Andrew C. Spears, Esquire Handler, Henning&Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman& Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 THOMAS, THOMAS & HAFER, LLP C J. A so Date: i oqj +V Scott D.McCarroll,Esquire �j 1- THE P R O T H O N'Q rA t( f Thomas,Thomas&Hafer,LLP I.D.No.92985 1013 JUL 22 PM 1: 49, 305 N.Front Street,6th Fir. P.O.Box 999 CUMBERLAND COUNTY Harrisburg,PA 17108-0999 (717)237-7131 PENNSYLVANIA smccarroll @tthlaw.com Counsel for Defendant Ashley McBride THELMA STEIDLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY;PENNSYLVANIA VS. NO. 3498-2011 CIVIL ACTION—LAW RICHARD MCBRIDE,DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants RY TRIAL DEMANDED PRAECIPE TO WITHDRAW DEFENDANT ASHLEY MCBRIDE'S MOTION TO COMPEL PLAINTIFF'S DISCOVERY RESPONSES- TO THE.PROTHONOTARY OF SAID COURT: Please mark as withdrawn Defendant Ashley McBride's Motion to Compel Plaintiffs Discovery Responses, which was field on or about July 19, 2013. Respectfully submitted, THOMAS,THOMAS & HAFER, LLP Date: �I Io,/, . Sco o 1;Esquire r 3 Attorney I.D. No. 92985 ' 1322792.1 Attorneys for Defendant Ashley McBride t v CERTIFICATE OF SERVICE ' I, Corey J. Adamson, for the law firm Thomas, Thomas &Hafer, LLP, hereby state that a true and correct copy of the attached document(s) was served upon all counsel of record by first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Andrew C. Spears, Esquire Handler, Henning& Rosenberg 1300 Linglestown Road Harrisburg,PA 17110 Christopher M. Reeser, Esquire Marshall Dennehey 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 THOMAS, THOMAS & HAFER, Corey J ams n Date:--711 I I THELMA STEIDLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA VS. NO. 3498-2011 CIVIL ACTION-LAW RICHARD MCBRIDE,DIANE MCBRIDE and ASHLEY,MCBRIDE,. Defendants Y TRIAL DEMANDED ORDER AND NOW, this day of // , 2013, upon consideration of Defendant Ashley McBride's Motion to Compel Plaintiff's Discovery Responses, it is hereby ORDERED and DECREED that said Motion is GRANTED. Plaintiff is commanded to provide full, complete, and verified responses, without objection, to Defendant Ashley McBride's Supplemental Interrogatories and Requests for Production of Documents within 20 days of the date hereof, or suffer sanctions upon further motion of Defendant. BY COU T: J. i Distribution Legend: , Andrew C. Spears, Esquire Scott D. McCarroll, Esquire Handler, Henning Rosenberg ,Thomas, Thomas &Hafer, LLP 1300 Linglestown Road POB 999 Harrisburg, PA 17108 Harrisburg, PA 17108 M c /Christopher M. Reeser, Esquire ; --<> C. o Marshall Dennehey Warner < MIR. Coleman& Goggin �';/ C o ° 4200 Crums Mills Road, Suite B P"-, Harrisburg, PA 17112 �. t 1Og. (] iA11 F. 2;x:3 OCT 29 APB II: c!+ CUMBERLAND COUNTY PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 03030-03184 Attorney for Defendants Richard and Diane McBride THELMA STEIDLE • COURT OF COMMON PLEAS • CUMBERLAND COUNTY Plaintiff • PENNSYLVANIA • vs. • No. 3498-2011 RICHARD MCBRIDE, DIANE MCBRIDE : and ASHLEY MCBRIDE : CIVIL ACTION—LAW • Defendants • JURY TRIAL DEMANDED PRAECIPE FOR CHANGE OF ADDRESS To the Prothonotary: Kindly note the change of address of counsel for Defendants Richard McBride and Diane McBride, from 4200 Crums Mill Road, Suite B, Harrisburg, PA 17112 to: Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 Phone: 717-651-3509 4 Respectfully submitted, MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: K' Christopher M. Reeser, Esquire Attorney for Defendant ID# 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Dated: October 28, 2013 } MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 03030-03184 Attorney for Defendants Richard and Diane McBride THELMA STEIDLE • COURT OF COMMON PLEAS • CUMBERLAND COUNTY Plaintiff • PENNSYLVANIA • vs. • No. 3498-2011 RICHARD MCBRIDE, DIANE MCBRIDE : and ASHLEY MCBRIDE : CIVIL ACTION—LAW • Defendants • JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman& Goggin, do hereby certify that on October 28, 2013, I served a copy of Defendants Richard and Diane McBride's Praecipe for Change of Address via First Class United States mail, postage prepaid as follows: Andrew C. Spears, Esquire Scott D. McCarroll, Esquire Handler, Henning & Rosenberg Thomas Thomas & Hafer, LLP 1300 Linglestown Road 305 North Front Street Harrisburg, PA 17108 PO Box 999 Attorney for Plaintiff Harrisburg, PA 17108 orney for Defendant Ashley McBride Christopher M. Reeser Scott D. McCarroll, Esquire Thomas, Thomas & Hafer, LLP I.D. No. 92985 305 N. Front Street, 6th Flr. P.O. Box 999 Harrisburg, PA 17108 -0999 (717) 237 -7131 smccarroll@tthlaw.com THELMA STEIDLE, Plaintiff vs. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants J GrFi�. INCNO IA:, 1iVI APR 28 CU!t1LEr L/ D COUNTY PENNSYLVANIA Counsel for Defendant Ashley McBride IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3498-2011 CIVIL ACTION — LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO ISSUANCE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party; 2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to this Certificate; 3. No objections to the subpoena issued have been made; and 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notice of Intent to Serve Subpoenas. Date: April 2(1, 2014 THOMAS S & HAFER, LLP Scott D. McCarroll, Esquire Attorney for Defendant Ashley McBride Scott D. McCarroll, Esquire Thomas, Thomas & Hafer, LLP I.D. No. 92985 305 N. Front Street, 6th Flr. P.O. Box 999 Harrisburg, PA 17108 -0999 (717) 237-7131 smccarroll @tthlaw.com THELMA STEIDLE, Plaintiff vs. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants Counsel for Defendant Ashley McBride IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3498-2011 CIVIL ACTION — LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Andrew C. Spears, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner, Coleman & Goggin 420o Crums Mills Road, Suite B Harrisburg, PA 17112 Defendant intends to serve subpoenas identical to the ones that are 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 any objections to this subpoena. If no objections are made, the subpoena will be served. Date: April , 2014 THOMAS, THOMAS & HAFER, LLP Scott D. McCarroll, Esquire Attorney for Defendant, Ashley McBride THELMA STEIDLE, Plaintiff vs. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3498-2011 CIVIL ACTION — LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of Pennsylvania 3399 Trindle Road Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copy of all UPDATED medical records pertaining to Thelma Steidle, DOB: 10/21/1966; SS# 171 -56 -8996, including but not limited to: medical records, evaluations, consultation reports, nursing notes, therapy notes, progress notes, records of other health care providers, reports of diagnostic studies, correspondence and bills from 9/18/2012 to the present to: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108. 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: Scott D. McCarroll, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108 -0999 TELEPHONE: (717) 237 -7131 SUPREME COURT ID #: 92985 ATTORNEY FOR: Defendant, Ashley McBride BY THE COURT: DATE: Seal of the Court Prothonotary /Clerk, Civil Division Deputy 1 029476.2 THELMA STEIDLE, Plaintiff vs. RICHARD MCBRIDE, DIANE MCBRIDE and ASHLEY MCBRIDE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 3498-2011 CIVIL ACTION — LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Cumberland Family Practice 4470 Valley Road Enola, Pa 17025 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: a complete copy of all UPDATED medical records pertaining to Thelma Steidle (DOB:10/21/1966; SSN: 171 -56 -8996) including but not limited to: emergency department records, evaluations, consultation reports, nursing notes, therapy notes, progress notes, discharge summaries, records of other health care providers, reports of diagnostic studies, correspondence, bills, notes, memos, e- mails, photographs, and any and all other documents contained in your file, including electronic documents from 11/20/2012 to the present. 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: Scott D. McCarroll ADDRESS: P.O. Box 999, Harrisburg, PA 17108 -0999 TELEPHONE: (717) 237 -7131 SUPREME COURT ID # 92985 ATTORNEY FOR: Defendant Ashley McBride BY THE COURT: DATE: 1135667.2 Seal of the Court Prothonotary /Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, Deborah A. Tamny, a Paralegal for the law firm Thomas, Thomas & Hafer, LLP, hereby state that a true and correct copy of the attached document(s) was served upon all counsel of record by first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Andrew C. Spears, Esq. Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 THOMAS, THOMAS & HAFER, LLP Deborah A. Tamny, Paralegal Dated: April /A , 2014 1135624.2 CERTIFICATE OF SERVICE I, Deborah A. Tamny, a Paralegal for the law firm Thomas, Thomas & Hafer, LLP, hereby state that a true and correct copy of the attached document(s) was served upon all counsel of record by first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Andrew C. Spears, Esq. Handler, Henning & Rosenberg 130o Linglestown Road Harrisburg, PA 17108 Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mills Road, Suite B Harrisburg, PA 17112 THOMAS, THOMAS & HAFER, LLP \\\ Deborah A. Tamny, Paralegal Dated: April2,5 , 2014 Andrew C. Spears Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@hhrlaw.com Attorney for Plaintiff(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THELMA STEIDLE, Plaintiff(s) v. RICHARD A. MCBRIDE, DIANE MCBRIDE, ASHLEY MCBRIDE, Defendant(s) 2011-3498 Civil Action - Law PRAECIPE Please mark the above captioned matter settled and discontinued. Dated: 1(64 14 HANDLER HENNING & ROSENBERG LLP Andrew C. Spears