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Home My WebLink About11-53494 I- 1uL ii-17 MHONG"Fk,' 20 11 SEF 14 PM 1: 1 UMBERLAI?C COL' S"' Matthew S. Crosby, Esq. PEPINSYLVANI A I. D.#69367 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiff Fax: (717) 233-3029 E-mail: Crosbya-hhrlaw.com CONNIE A. LEED and IN THE COURT OF COMMON PLEAS RAYMOND LEED, her husband, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 11-5349 Civil Term HOLLY WILLEBRAND, CIVIL ACTION - LAW Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF DAUPHIN I, MATTHEW S. CROSBY, hereby certify that I served the Civil Writ of Summons in the above-captioned matter on Defendant Holly Willebrand, by Certified first-class United States mail,Restricted Delivery, return receipt requested, and said document was received by Holly Willebrand, on August 30, 2011, as evidenced by the signed return receipt card, attached hereto and made a part hereof, along with the copy of the transmittal letter and copy of the said Writ. Sworn to before me and subscribed this Dday of zr 2011 NOTARIAL SEAL VERA F FREED Not ry Public NgOt?1lANNA TVW. DAUPHIN My My Commission Expires Aup 28, 2015 AL) ¦ Complete items 1, 2, and 3. Also complete Item 4 If Resdicted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: o LLy LL-13e'w 13-773 Ckie IAaK 01rc NO("P6o(I VA 23513 -- v3 A. Sig 0 r3 17?v Lti? t vt 3 X Agent G ? Addressee B ved by (Prlntgd ) C. Date of Delivery D. Is delivery dress d'Ifferent from Rem 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type Certified Mail ? Express Mail 1 Registered ? Retum Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Numby-- ' (rmnsferfrom 7010 3090 0001 8671 7211 PS Form 3811, February 2004 Domestic Return Receipt SC - L.tGd Zj-qG 192¢95.02-M-1540 August 26, 2011 Holly Willebrand 3773 Chatham Circle Norfolk, VA 23513-5304 VIA CERTIFIED, RESTRICTED MAIL Re: Connie A. Leed, et vir. v. Holly Willebrand Cumberland Co. CCP No. 11-5349 Incident of 8/20/2009 Dear Ms. Willebrand: In connection with the above-captioned matter, enclosed is a Writ of Summons issued against you, which has been filed with the Court of Common Pleas of Cumberland County, Pennsylvania. We are serving this upon you, the Defendant in this matter. You should forward this Writ to your insurance company or your attorney as soon as possible, so that an appropriate and timely response can be made on your behalf, which is mandatory. Thank you for your attention to this matter. y truly yours, • IDLER HENNING & ROSENBERG LLP I n Postage $ thew S. Crosby 0 R candied Fee Postmark Return Receipt Fee (Endorsement Required) Here Restricted Delivery Fee :3 (Endorsement Required) r T1 Q Total Postage & Fees $ r=1 O Sent Sireet,Apt.No 0 .• ?? -- -- - ------------ [? 3 otPOBoxNo. J J . ----- Cja_ - - City ZIP+4 o a • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff(s) & Address(es) CONNIE A. LEED and RAYMOND LEED, her husband 1219 Balthasar St. Harrisburg, PA 17112 VS. Defendant(s) & Address(es) HOLLY WILLEBRAND 1323 Iveywood Rd. Virginia Beach, VA 23453 il T C N Ci ase o. v er 0 . lag C-- Civil Action :9 'IM m G. en cn y, ?z v a -+c PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Z --t ?t9 -Cj z-n s,. cs-"n -)v .. co Issue summons in the above case Writ of Summons shall be issued and forwarded t Attorne heriff (Please Circle choice) Date Signatu # orney Print Name: Matthew S. Crosby, Esq. Address: 1300 Linglestown Rd. Harrisburg, PA 17110 Telephone #: 717-238-2000 Supreme Court ID Number: 69367 TO: • 0 • s 0 WRIT OF SUMMONS YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU -DArUL D D I?IA ?? L(- Prothonotary/Clerk, Civil Division Date: - by Deputy TRUE COPY FROM RECORD IA Testimony whereof, I here unto set my hand and the seal of said C urt at Carlisle, Pa. This _ R day of 20 ro notary P C7? ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : cS -, CONNIE A. LEED and RAYMOND LEED, ?rrnn o M- her husband, NO.: 11-5349 Plaintiffs Z ° V. =- D_' N 1711 HOLLY WILLEBRAND, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Defendant's Loss of Consortium Interrogatories Addressed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Matthew Crosby, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 EAGER, SPINELLO, QUINN & STENGEL DATE: I ) Le. BY: George H. er, Esquire Attorney 2;77K77,4 Defendant 1. D. No. 0 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONNIE A. LEED and RAYMOND LEED, her husband, Plaintiffs V. HOLLY WILLEBRAND, Defendant NO.: 11-5349 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of Defendant's Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Matthew Crosby, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 DATE: 1 V EAGER, STENGEL, QUINN & SOFILKA BY: George H-Sage r?EAL Attorney for D ant I.D. No. 277 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ire ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONNIE A. LEED and RAYMOND LEED, her husband, Plaintiffs V. HOLLY WILLEBRAND, Defendant NO.: 11-5349 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE C rnai Z:m x (n r- r-<C; vC-) I HEREBY CERTIFY that I have this day served an original of Interrogatories of a •c -r -a N F-0 F - art a4? Defendant Addressed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Matthew Crosby, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 EAGER, STENGEL, QUINN & SOFILKA DATE: I I 1 BY: I_--- George H. Eag squire Attorney for ndant I.D. No. ;?ii'llllee 1347 Fr Pike Lancas er, PA 17601 (717) 290-7971 ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONNIE A. LEED and RAYMOND LEED, her husband, Plaintiffs V. HOLLY WILLEBRAND, Defendant NO.: 11-5349 cr, ? C) v? -v s N c? ?z a t:J --ry JURY TRIAL DEMANDED ANSWER WITH NEW MATTER You are hereby notified to plead to the within New Matter within 20 days from the date of service hereto or a default judgment may be entered against you. AND NOW COMES DEFENDANT, BY AND THROUGH HER ATTORNEY, GEORGE H. EAGER, AND FILES THE FOLLOWING ANSWER: 1.-2 Denied for lack of information. The Plaintiffs are not personally known to Answering Defendant and, accordingly, this paragraph can neither be admitted or denied. 3. Denied. Defendant's last known address is 1323 Ivywood Road, Virginia Beach, VA 23453-1512. 4. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). 5. Admitted. 6-12. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in her favor and against the Plaintiff on all claims set forth in Plaintiffs Complaint. COUNTI Connie A. Leed v. Holly C. Willebrand 13. Paragraphs 1 through 13 of Defendant's Answer are incorporated herein by reference as though fully set forth. 14-15. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Answering Defendant respectfully demands judgment in her favor and against all other parties together with the costs of this action. COUNT II - LOSS OF CONSORTIUM Raymond Leed, Sr. v. Holly C. Willebrand 16. Paragraphs 1 through 15 of Defendant's Answer are incorporated herein by reference as though fully set forth. 17-19. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Answering Defendant respectfully demands judgment in her favor and against all other parties together with the costs of this action. NEW MATTER 20. Paragraphs 1 through 19 inclusive above are incorporated herein by reference and made a part hereof. 21. Plaintiffs' recovery is barred and/or limited pursuant to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Act, 75 Pa.C.S.A. 1701, et. seq., and Answering Defendant hereby asserts all of the rights and defenses available to them under the aforementioned act. 22. Plaintiffs' claims are barred and/or limited pursuant to the applicable Statute of Limitations, the relevant portions of which are incorporated herein by reference. 23. Plaintiffs' claims are barred and/or limited by the tort thresholds, applicable by election or law, of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. §1701, et. seq. 24. Plaintiffs' claims are barred and/or limited by the preclusion of pleading, proving and/or recovering special damages as set forth in §1722 of the Pennsylvania Motor Vehicle Financial Responsibility Law, Pa.C.S.A. §1722. 25. Plaintiffs' claims are barred by the affirmative defenses identified in Pennsylvania Rule of Civil Procedure 1030, including but not limited to (a) waiver; (b) estoppel; (c) statutes of limitation; (d) laches; (e) illegality; (f) release; (g) impossibility of performance; (h) fraud; (i) assumption of the risk; and Q) payment. WHEREFORE, Answering Defendant respectfully demand judgment in her favor and against all other parties together with the costs of this action. EAGER, STENGEL, QUINN & SOFILKA DATE: 11- )G-11 BY George H. Eager squire Attorney for endant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 VERIFICATION I, George H. Eager, hereby verify that the Defendant HOLLY WILLEBRAND is outside the jurisdiction of the Court and that his Verification cannot be obtained within the time allowed for filing a responsive pleading. I am making this Verification as a person having sufficient knowledge or information and belief to deny the matters as set forth in the Complaint upon my knowledge as discerned from the Police Report. I understand that false statements contained in my Answer are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. BY: George H. E er, Esquire DATE: /I- ) (P -11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer with New Matter upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Matthew Crosby, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 DATE: /)-)G -11 BY: EAGER, STENGEL, QUINN & SOFILKA George H. Eager s Attorney for a ant I.D. No. 2 1347 Fr ille Pike Lancaster, PA 17601 (717) 290-7971 re _ 3 FILED-OFFICE lp"((ON ? yF 1 E_ f ?aU f{'•11''? It.1 2011 NOV 22 PM 12: 33' CUMBERLAND COUNTY PENNSYLVANIA Matthew S. Crosby, Esq. I. D.#69367 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax : (717) 233-3029 E-mail: Crosby@HHRLaw.com CONNIE A. LEED and : IN THE COURT OF COMMON PLEAS OF RAYMOND LEED, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No. 11-5349 HOLLY WILLEBRAND, CIVIL ACTION -LAW Defendant PLAINTIFFS' REPLY TO DEFENDANT. HOLLY WILLEBRAND'S NEW MATTER AND NOW, come the Plaintiffs, Connie A. Leed and Raymond Leed, her husband, by and through their attorneys, HANDLER, HENNING & ROSENBERG, LLP, by Matthew S. Crosby, Esq., and reply to Defendant, Holly Willebrand's New Matter as follows: 20. Paragraph 20 is a paragraph of incorporation and, therefore, no response is required. 21. Denied. The allegations in Paragraph 21 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. -1- 22. Denied. The allegations in Paragraph 22 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 23. Denied. The allegations in Paragraph 23 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 24. Denied. The allegations in Paragraph 24 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. 25. Denied. The allegations in Paragraph 25 contain conclusions of law to which no response is required. If a response is judicially determined to be required, the averments contained therein are specifically denied. WHEREFORE, Plaintiffs respectfully request that this Honorable Court deny Defendant's allegations and enter judgment in favor of the Plaintiffs. Respectfully submitted, DATE: 1111I)II HANDLER, HENNING & ROSENBERG, LLP By C -Q. ':?' Matthew S. Crosby, Esq. Attorney I.D. #69367 Attorneys for Plaintiffs -2- VERIFICATION PURSUANT TO Pa. R.C.P. No. 1024(c) MATTHEW S. CROSBY, ESQ. states that he is the attorney for the party(ies) filing the foregoing document; that he makes this Complaint as an attorney and verifies that it is correct and accurate to the best of his knowledge, information and belief and that this statement is made subject to the penalties of 18 Pa. C.S.A., Section 4904 relating to unsworn falsification to authorities. cr---==?L MATTHEW S. CROSBY, ESQ. DATE: 1 Matthew S. Crosby, Esq. I. D.#69367 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiff Fax : (717) 233-3029 E-mail: Crosby@HHRLaw.com CONNIE A. LEED and : IN THE COURT OF COMMON PLEAS OF RAYMOND LEED, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. HOLLY WILLEBRAND, Defendant : No. 11-6349 : CIVIL ACTION -LAW CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendant, Holly Willebrand, by sending a copy of the same to her counsel of record, George H. Eager, Esq., EAGER, SPINELLO, QUINN & STENGEL 1347 Fruitville Pike, Lancaster, PA 17601 by United States Mail, regular service, in Harrisburg, Pennsylvania on November LL, 2011. HANDLER, HENNING & ROSENBERG, LLP By Cr,__-Q_ Matthew S. Crosby, Esq. Attorney I.D. #69367 DATE: ?+ Attorneys for Plaintiffs ? t `HIE PRO TNONOTAR)' Matthew S. Crosby, Esq. I.D. # 69367 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax: (717) 233-3029 E-mail: Crosby@HHRLaw.com IN THE COURT OF COMMON PLEAS 2012 JAN 20 PM 1: 09 CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA CONNIE A. LEED and RAYMOND LEED, her husband, Plaintiffs : 11-5349 V. HOLLY WILLEBRAND, Defendant ACTION - LAW CERTIFICATE OF SERVICE On January 17, 2012, 1 hereby certify that a true and correct copy of Plaintiffs' Answers to Defendants Interrogatories, Plaintiffs' Responses to Defendants Loss of Consortium Interrogatories and Plaintiffs' Responses to Defendants Requests for Production of Documents was served upon the following by depositing same in the United States Mail, in Harrisburg, Pennsylvania: George H. Eager, Esq. EAGER, SPINELLO, QUINN & STENGEL 1347 Fruitville Pike Lancaster, PA 1 H DLER, H & ROS RG, LLP Dated: Matthew S. Crosby ORIGINAL r. , . r. ,. `,. II g(^ C C" f I L. T P -G:,11 I'll , ' 1;;, I I..' , CUUMBERLAND COONIT Y PENS r'L`,ik 1A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONNIE A. LEED and RAYMOND LEED, her husband. Plaintiffs NO.: 11-5349 V. HOLLY WILLEBRAND, Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that, (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: -a /a q 1 squire George H. EagerZdant Attorney for Def I.D. No. 27740 1347 Fruitville ike Lancaster, PA 17601 (717) 290-7971 PENNSYLVANIA COURT OF COMMON PLEAS • COUNTY OF CUMBERLAND COUNTY Connie A. Leed And Raymond Leed, Husband And Wife CIVIL ACTION - LAW VS. Holly Willeband, Defendant NO. 11-5349 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Provider: Record Type: Holy Spirit Hospital Radiology Holy Spirit Hospital Medical Drayer Physical Therapy Institute All available Orthopedic Institute of PA All available David Ferner All available Golden Living Center - Blue Ridge Mountain Employment Pinnacle Health at Arlington All available West Hanover MRI All available Quantum Imaging All available Tristan Associates All available Schein Ernst Eye Associates All available TO: Matthew S. Crosby, Esquire note: please see enclosed list of all other interested counsel Litigation Solutions, LLC ('LSLLC') on behalf of George H. Eager, Esquire intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Date of Issue: 1/31/2012 Litigation Solutions, LLC on behalf of: CC: George H. Eager, Esquire of Eager, Stengel, Quinn & Sofilka - CIVIL ACTION - George H. Eager, Esquire LAW Defense If you have any questions regarding this matter, please contact: Litigation Solutions, LLC (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 COUNSEL LISTING FOR CONNIE A. LEED AND RAYMOND LEED, HUSBAND AND WIFE VS. HOLLY WILLEBAND, DEFENDANT County of CUMBERLAND COUNTY CIVIL ACTION - LAW Counsel Firm Counsel Type Crosby, Esquire, Matthew 1300 Linglestown Road Ste. 2 Harrisburg PA 17110 P: 717-238-2000 F: 717- Opposing S. 233-3029 Counsel -:0lv1t f'u1V,"-0.AL7H err pE't ?SYi° 'td`tr. Connie A. Leed And Raymond Leed, r{NO. 11-5349 Husband And Wife . VS. Holly Willeband, Defendant SUBPOENA TO MODUCE DOCUMENTS OR, THINGS FoR DISCOVERY PURSUANT To RULE 400,22 TO: Dra er Physical Therapy Institute (14=6 of P== or Eatity) Withna twentY (20) nays after swAce otak tubpomr:e, you art ordered by the court to prod= tbo foUowing docvaremts or Wu$s- f PLEASE SEE ATTACHED RIDER It 101 TowneS uare Way, Suite 251 Pittsburgh, PA 15227 (Addttss) You may deliver or M03 '4011 copies of the &CM&W or prv _ , ` Wmga request d by this V-4oeas, togs fiat with the certificate of comphance, to the patty =king nest at tba addxzss tisteri above. You hava the right to scmk in advance dae reasonable cost of prep xtiag; wgiee or producing the. thugs sou& If you W to produce W documents or tbinp mquired by this subpl?w vritbin twenty (20) days art its service, the Party serving this subpaeut um y seek a c o6urt order 0rQpolWg you to comely with it TMS SUBMEMA. WAS ISSUED AT TRB REQtTEST OF THE FOLLOMM PM( V: NAIZ: George H. Eager, Esquire ,ADDRESS: 1347- Fruitville Pile ran aster PA, 1,7601 TEI~S OHMM: 717-290-77T SE)PREM COURT ID # 2 7 7 4 0 ATTORM FOR: Defense Dab: .?240? Of the c'"d BY nour'y, c! Diaisi pity Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Drayer Physical Therapy Institute 2805 Old Post Road Suite 210 Harrisburg PA 17110 Attention: Records Department Subject: Leed, Connie SS#: 9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Films (X-rays, MRIs, CTs), Film lists --;01vJ34 .-V- SAL7K OF MOISYi :'ACALA. ? s?Ul r r. , T r- L'):J: B ERL.L.i Tj-.t Connie A. Leed. And Raymond Leed, gilt IF. Nn.. 11-.L349 Husband And Wife vs. Holly Willeband, Defendant SUBPOENA TO MODUCR DOCUMNTS OR T MGS F4R DISCOVERY PURSUANT TO RULE 40012 TO: . David Ferner (Naas ofPasou or Entity) Wit & txtuty (207) dap after cerviaa of this sulapoms, you are ordered by tha court to produce The following docu mu 07 things: PLEASE SEE ATTACHED RIDER it. 1 Towne S ware Wa Suite 251 Pittsburgh, PA 15227 (Address) You may deliver or nufl legible copies of dw documents or pre ? • ` Wap request d by this mbpoess, together vvA the caMcake of amen, to the poly =a*, th?? ' ' at the address listed ahove. You have &a ri jtt to seek in advance the reasonable cost uag a copies or producing the Wav sougk If you fail to produce the docuaaeata or thinp required by this subpyea witbin twenty (20) days after iatc service, the party serving this subpoena may seek a moat order corapelAng you to tomply with it n M M SUBPOM A WAS ISSUED AT TFM FSQUMT OF THE FOLLOVM TG t'MOP: NAME: George H. Eager, Esquire ADDRESS: '-:k4 7 F r» ; L v -i l l e. P_ i k e Tnn(-Aster PA, 1,7601 TIELVEt M 717-290-7971 SUPPJDM COURT ID g 277 40 ATTORNEY FUR: De EZ . _ Date: llc6 // ?. 941 of the dovrt BY THE r.'ivfl Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Dr. David Ferner 4301 Londonderry Road Harrisburg PA 17109 Attention: Records Department Subject: Leed, Connie SS#: 9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from all to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Films (X-rays, MRIs, CTs), Film lists `-.01valle' 4 rf i.Y?+l S1r ?Lri Yom` . Y .'1i Connie A. Deed And Raymond Leed, NQ, 11-5349 Husband And Wife VS. Holly Willeband, Defendant SUBPOINA. TO PRODUCE DOCUMENTS OR TM GS FOR DISCOVERY MMSUANT TO RULE 4009.22 TO: Golden Living Center - Blue Ridge Mountain (14=0 of Paton or Entity) Fi?it4ia "M" (20) days S&r service of t.6is subpoena, YOU are ordeaed by tbo coati' m prod= the Mowing dosumcata or things: PLEASE SEE ATTACHED RIDER Suite 251 Pittsburgh, PA 15227 it 101 Towne Square Way, -_-T- - - - (Addmu) You, may deliver or mail kgilk copies of the doemem or prod thing: requeded 4y ttlis n4oma, to edw vft ft tedfita C of compua ae, to the j uty making ttl?;? U thG dGbreSt liStCd above. You bAvm the right to seek in a&&me the reasonable cost of pr+apopirs as producing the things nought. If you fig to praduoe the documents or tltiap•requimd by this subpNem within twenty (20) days att.its service, the party saving dais svbpoans my seek it court order cmVelkjag you to comply with it THIS SUBPOM4A WAS ISSUEL AT TAE PAUEST OF TIE FOLLMMIG PERSON: NAME: George H. Eager, Esquire ADDRTSS: 1 -3a7 Frlli tville Pike 1.4n?;aGter PA 17601 TET..EMOM: 717-290-7971 SUPRZM COURT ID g 2 7 7 4 0 ATTORNEY FOR Defense rf the By m Fradmao , Ntat Divisio Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Golden Living Center - Blue Ridge Mountain 3625 North Progress Avenue Harrisburg PA 17110 Attention: Human Resources Department Subject: Leed, Connie SS#: 9371 Date of Birth: 08/21/1953 Requested Items: Complete copy of employment files Application for employment, preemployment physical, date employment began, worker's compensation claims and medical reports, performance evaluations, year end payroll records for each year of employment, dsciplinary notices, leave of absent dates and reason for leave and date of termination. .'.!0WA&1V,TAL7H OF Connie A. Leed And Raymond Leed, • PiI; Iis. NO. 1-5349 Husband And Wife VS. Holly Willeband, Defendant SUBPOENA. TO PRODUCE DOCIJMNTS OR TRM S FOR DISCOVERY P`URSUAM TO RULE 4009.22 'r`?:, of Spirit Hos ital - Radiology ... ,. (I`tara0 of Perron or Entity) Within twenty (20j days alter ttrvica of this subpor=, you are ordered by the c curt to produce the foUawing dot= U or Wags: 1 a - a PLEASE SEE ATTACHED RIDER at 101 Towne___Square Way, Suite 251 Pittsburgh, PA 1522'7 --- - (Addtmsa) you may dsuver or mu1 kg'ble copies of &a documents or ? Wags requested by this .mbpoena, tagather wj& the tert:5icate of compliance, to the party making tI at dw sddn= liokd above. You bane the right to sdtk in advam-. the reasonable cost ofprep"', copies or producing the If you fill to produces the doo mauts or things mashed by this subp6m within tw" (20) days :itlx fta rrzvice, the gntl! taving this subpoeat may seek a craurt order camp C108 you 10,towly with it THIS SUBFOMTA WAS ISSUED AT TT EPYQUEST OF TEM FOLLOWIM FER. ON: NAM: George H. Eager, Esquire ADDMS: J-3-17 uitville Pike a T AnQaster PA, 1'7601 t_ 38I&SC71a- 717-290-7971 SPREb+I13COMIDP 27740 AI'I'OPIW FDk: D e.: an s e ,..... ,.... Date: 6?C /'/ l of the urt BY THE Pro , ?vrl Davis ax Deputy Rider to Subpoena Explanation of Required Documents and Things TO. CUSTODIAN OF RECORDS FOR: Holy Spirit Hospital 503 North 21st Street Camp Hill PA 17011 Attention: Radiology Films Library Subject: Leed, Connie SS#: 9371 Date of Birth: 08/21/1953 Requested Items: Please remit: Complete copy of any and all diagnostic films, film lists and film reports from 1/1/2000 to present, including X-Rays, MRI, and CT scans. •» ?iv?rlw?tr?t? i ? ?.at ??????? Lt :?s.t?fl'. • Connie A. Leed And Raymond Leed, Pat III- 5349 Husband And Wife ,NQ. 1, VS. Holly Willeband, Defendant SUBPOENA TO MODUCE DOCUM14TS OR THINGS FOR DISCOVERY PMUU"T TO RULE 4009.22 'I'ts: jj2lv,-Sj?irit__Hospita_l - Medical (Neese of Pena or satity) Within twenty (20) drys aftGt servico Of this subpoena, fmu are Ordered the court to irraduca th fotloari? dacutm?eats of thingC: PLEASE SEE ATTACHED RIDER It 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 You may d*Um or mag k016 ropias of &a dacttments or pro . ` tags requead by this .n*"etea, togct2ust with the trrti£eaie of compbanee, to tha party ma =king t6: hest at the address Wad above. you have the fi& to seek in &&&we the muoaable cost of pmpcopiaa ox producing the ftp soup ' If you fAq to petiodm tha de cuweat: of Unp taquked by tbas subp6m within twmty (20) days after its teeviea, the patty jawing this subpocns my seek a court order campej#ag you to comply with it M SUBPOENA WAS iSSM AT THE PAUFS'I' OF THE FOLLOW11TO PEU011: NAME: George H_ Eager, Esquire ,AI DRUS: - 3.4 7 F r i j i t"l l e P i ke T.;:?nr??Pr PA, 17601 ! TOWROM: 717-290-7971 SVPRBMH CO ID 0 2 7 7 4 0 AT.C4 UGYFOR. Drte: ?'o // -42 l of the BY THE Pmtho tart', .._,.. DM sio Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Holy Spirit Hospital 503 North 21st Street Camp Hill PA 17011 Attention: Medical Records Correspondence Subject: Leed, Connie SS#:9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all medical records from 1/1/2000 to present, including records, charts, test results, reports, correspondence, office notes, patient intake forms, and computerized records. -:??JIYD=f?:ly"?'n..?t??..rH r1s ?'??ff?'?'Yi` »?'t•i?:-. . Connie A. Leed And Raymond Leed,*tLID. -,11-5-349w Husband And Wife ?-•- VS. Holly Willeband, Defendant SUBPOENA, TO PRODUCE DOCUIZNTS OR TRIOS FOR DISCOVERY PURSUANT TO RULE 40042 TO: QgLLoipedic Institute of PA (wxw ofpwolk or Entity) Within ttve»ty (20) days after service of this cubpoana, you art ordcrad by the court to produce the tal owing docYUOamu at tWngt: j E e PLEASE SEE ATTACHED RIDER PA 15227 At 101 TownQ Sauare_Way,_ Suite 251 Pittsburgh, you m=y dative r or mW leipble copies of tha downew or PM 4' LWASa regUGSW by files mvbpaaus, tose6w whit tha certificate of rrnupliance, to the patty making tl of tha addms Wed shave. You have the right to sale is advance the remnable cost of prep ad ? copw or pxoducin the, Wap ao, r If you fad to pt*duce the documnts or Ww •regct and by thi3 subpl = wjd a twealy (20) days niter itr sctvica, ttu party serving this subpoern may Seek a court ordef compelos you tb cotwy with it MS STMOMA WAS ISSM AT TMPZQLWT OF THE POLLOWI110 pERSS014: NAME: GQor2e H. Eager, Esquire ,AD'DRUS: , `tom Rrti,; = 1le --Pike r ?etPr PA, 17601 IKZPHOM: 717-290-797-1 SUPRElO COLT,K.T ID 2 7 7 4 0 ArTUR BY POP- rnPfPnse Dab:?o?? f •2 Seal of the court Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Orthopedic Institute of PA 450 Powers Ave Harrisburg PA 17109 Attention: Records Department Subject: Leed, Connie SS#: 9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Films (X-rays, MRIs, C7"s), Film lists ? ?lYfl-f ?2?''??A F . j ?t ?1F loE'rT?•I;?'? i ? :?'t•?"sr`. . Connie A. Leed And Raymond Leed, = eusl;? Husband And Wife ,_No_ .11-5349 vs. Holly Willeband, Defendant SUBPOENA TO PRODUCE DOCUM NTS OR THINGS FOR DISCOVERY P'UNUAM TO RULE 400.23 TO: Pinnacle Health at Arlington (NamofPersoa or Eatity) - - - _- Withia tftnty (20) days attar service oftWt tubpaena, YOU ara ordered by the court to proltce the fGHOwing dnr+tuunts ar thing: PLEASE SEE ATTACHED RIDER at 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (A ss) You rosy deliver or anvil tegibla co* of &a docano mn or pr &iugr regwmud by this mbpoetm, together with the terl CM4 Of compliInCe, t6 ftb patty M-- th ' giiett at the sddress listed above. You have the rift to aetlt is advance @u rGSOnaYste cost of preparutg? copes or producing the bugs tougbt. If you far! to prodwe 6a documents or ddw required by this subpb = widga twee (20) days after .itt service, & party wrviug Us subpow my seek a cowt order compe" you to comply twaith it Y TMS SUBPOWA WAS ISSUED AT THE REQUEST OF TEM FOLLOWItTo PERSON: MME: Georrge H. Eager, Esquire ADDRUS: 1_47 _LLu tvil_le Pike 7,an aster PA, 17601 kF TM-SP3OM: 717-290-7971 SMRSW COURT O P- 27740 A.MMNEYMR: Defense Daft:--- lj.2(,o zl?e -- aal of Cove BY ?1Y, sn? I??ixion Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Pinnacle Health at Arlington 805 Sir Thomas Court Harrisburg PA 17109 Attention: Records Department Subject: Leed, Connie SS#:9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Films (X-rays, MRIs, CTs), Film lists 014J r t t't .fit W a A rjr pC.Y•ltIa Y% ::w't II,= TZ, Connie A. Leed And Raymond Leed, Fill., It. 11-5349 Husband And Wife VS. Holly Willeband, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY FUR.SUAN'T TO RULE 400P,22 TO: Quantum. ima in (WAMofN am or Entity) Widua tftaty (28) drys after service of flat subpoena, you are ordered by? the court to produc the fo Uowing documents or things: y F PLEASE SEE ATTACHED RIDER at 101 Towne _S_q_uare Way, Suite 251 Pittsburgh, PA 15227 - - - - (Addaese) - - - You may deUm or mail legible copies of the domnents or pradlt Wage roque*W by tbuis mbpoens, together with the certificate Of G4 Ge. tdl the party making tEt0quest at the address Wed above. You bay the right to salt is advance the reasotubie coat of preparna copin or pzoducizg the edugs sougk ° If you W to produaa the &xumemu or 0quired by this subp" a Aritbia twenty (20) days aRer.its mer *4, the party zarvW tart subp m& testy seek a c-ott order rooa e4 ng you to to=gy with it. T= SUBPOM A WAS ISSUED AT THE FAMST OF THE FOLLOW1110 PPMON: Georqe H-.__Eager, Esquire ADDMS: 1 'i4 r,;i ttyille- Pike T,anr.aster PA, 17601 t 4 'IELEp'H(3NB: 717-290-7971 SUPRI1M COURT ID # 2 7 7 4 0 ATPORNSY FOR. D- f e n s e ?..,. cal of the Court Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Quantum Imaging 629 D Lowerther Street Lewisberry PA 17339 Attention: Records Department Subject: Leed, Connie SS#: 9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: s Medical records (charts, test results, reports, correspondence, office notes) Films (X-rays, MRIs, CTs), Film lists OF pall-TSYL `. far. Connie A. Leed And Raymond Leed, Husband And Wife :ustt Nom, 11-5349 VS. Holly Willeband, Defendant AMMENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TJ: Schein Ernst Eye Associates 044 of Persor, or Entity} W ititia twenty (20) days after tervict of this subpoena, you ue ordered by the court to preduca the fbuoarint dot=mtt or things: s PLEASE SEE ATTACHED RIDER at 101 Towne Square Way, Suite 251 Pittsburah, PA 15227 (Addmaa) You may deliver or mail kgtble copier of the doc=ents or pro Wags requested by this subpoena, tom with the caricate of coapWnce, to the party mr3ciag t6 pert at the :ddxrsx Wed above. You }nave the tot to seek in Ova= the reasonable cost of prep atu? copies or producing the &Wgs sougbt ' If you fag to prodwe the documnix or thiM equind by this subpE? W wifhin tweaty (20) days afkr its sexvice, tba puty owing ibis subpoena may seats a wouat order cotapc},j you to coatply wi& it M SUBPOEI A WAS ISSt7E1`i AT THE PAMST OF THE POLLOVrffT(j- P 01I NA M: George H. Eager, Esquire ADDRESS: 1347 Fruitville Pi e Lancaster PA, 176 -; 717-290- SUPRI M13CCMr17) P 27740 AT1V;lt W1a0R Defense Daft: 142- ?e S ! of t6t C:onrt BY THASquip ta'ht, Civa Division Deputl? Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Schein Ernst Eye Associates 2509 North Front Street Harrisburg PA 17110 Attention: Records Department Subject: Leed, Connie SS#:9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) a Films (X-rays, MRIs, CTs), Film lists .°.? rk?.'1vMMALM 07 Connie A. Leed And Raymond Leed, ?LEt II,. Husband And "Wife i _ No. -1-5349 VS. Holly Willeband, Defendant SUBPOENA TO PRODUCE DOCU XNTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4004.22 TO: Tristan Associates (Nnne ofPeam or Etaty) Flitlaiu tureaty (20) daY0 after service of this subpoarxa.'M are ordered by the court to produce the folLoaiAt docaMAUtt or tbials: PLEASE SEE ATTACHED RIDER at101 Towne Square Way, Suite 251 Pittsburqh, PA 15227 tAddnstj _ _ You may deliver or map leipble copies of the documents at prod 6*8 rmpco td by this .14oemx, togt6a wilt the cerlificata of compliance, to the party malting tb est at tU address fisted gwye. You hs.%,g the right to seek iq advance the reatonabie cost of Prep atsag copw or producing the things toughL,. f if you fag to produce the dreurnents or dbp mp*ed by this sub *a within twenty (20) drys after its service. the pom vervinB ft subpoena may ftek a court order compels you ui comply with it TM SUBPOENA WAS ISSUED AT TMIQUEST OF THE FOLLOW111ti PERE0I1: NAM: George H. Eager, Esquire ADDMS: ] .347 Frui ty11le Pike T.anQaster PAS 17601 k' TELEPHONE: 17 -7 9 0- 7 9 71 SUPREMCDt1RTlD# 27740 AT Onw FQR: De f n s e Dee: ( J,?) (0 / I a 96f 4 * Clot BY THE f rivt Division Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Tristan Associates 4518 Union Deposit Road Harrisburg PA 17111 Attention: Records Department Subject: Leed, Connie SS#:9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from 1/1/2000 to present regarding the above-named patient, including but not limited to: s Medical records (charts, test results, reports, correspondence, office notes) ® Hims (X-rays, MRIs, CTs), Film lists F?7,?lvttYf??'`?it'FA1,.TH?J?' P?11????Ci.;'??ii'U=. Connie A. Leed And Raymond Leed, File li:. NO. 11-5349 Husband And Wife VS. Holly Willeband, Defendant SUBPOENA TO PMDUCE DOCUMNTS OR T$II GS FOR DISCOVERY PURSUANT TO RULE 4000.22 T0- West Hanover MRI (Naaaa of Pwoa or Ewty) Wi6in t'ovtnty (20) days aftrr servka of this subpoena, -you are Otdaced by than ceuzt to product the following documen u or t jov: PLEASE SEE ATTACHED RIDER It 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (Adds:) YOU MY daliver or = 9 k9t1-ble copies of the doca ats or pr all' F p MpedKd by this a>l?poeaa, totedw wish the c%1Zcak of cc? =e. to the pat't;t maidlIg at the adttrrss liCtrd aEsove. You have tha right to srelc in advraxa tt?se reasoashle cast of preptrtagmet or p?todietzin? the thisig::aug]? ; T If you fag to p o&m 6* documents or thia? required by this subp" witkiu twt* (20) dales aft" its M-40a, ft P" *GMIA2 this subpoena ttmy°seek s eoVrt ordet'ratap*Wo& You to co=yly vntlt it TEf'tS SUBPOl NA WAS IS4CtixL AT THS R.SQMST OF THE FOLLOMIG FERS014 NAM: George H. Eager, Esquire ADDRUS. 347 Fruitville Pike Lancaster PA, 17601 ?. TMEPEM 717-290-7 S[iPl Capj1R,Z' ID ty 2 7 7 4 0 ArIY FOR,; Defense Daft: .._.. 1d2(p l a ,..r..,. Sea of the vet BY UR.. '! Divisia?a nor Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: West Hanover MRI 8012 Bretz Drive Hummelstown PA 17036 Attention: Records Department Subject: Leed, Connie SS#:9371 Date of Birth: 08/21/1953 Requested Items: Please remit: a complete copy of any and all documents in your possession from 11112000 to present regarding the above-named patient, including but not limited to: s Medical records (charts, test results, reports, correspondence, office notes) 9 Films (X-rays, MRIs, CTs), Film lists CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Matthew Crosby, Esquire Handier, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 DATE:'C2 /"? / a- BY: EAGER, STENGEL, QUINN & SOFILKA George H. Eager, E Attorney for Defend I.D. No. 27740 1347 Fruitville Pike( Lancaster, PA 176( (717) 290-7971