HomeMy WebLinkAbout04-4436
JAMES B. FARROW AND
HEATHER FARROW,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. C>4 - 41./3b.
C",; l'-T E.n..vYJ
VALERIE FETTER
CIVIL ACTION - LAW
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served, by entering a written appearance personally or by
attorney and filing in writing with the Court your defenses or objections to the claims
set forth against you. You are warned that if you fail to do so the case may proceed
without you and a judgment may be entered against you by the Court without further
notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff, You may lose money or property or other rights important
to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE PA 17013
(800) 990-9108
~~/
Richard E, F ebum, Esctuire
FREEBURN & HAMILTO~
4415 North Front Street
Harrisburg PA 17110
(717) 671-1955
LD. #30965
Date: 8/31/04
Attorney for Plaintiff
JAMES B. FARROW AND
HEATHER FARROW,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
VALERIE FErrER
CIVIL ACTION - LAW
Defendant
NOTICE
USTED HA SIDO DEMANDADO/A EN CORTE, Si usted quiere defenderse de
estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de
plazo al partir de la fecha de la demanda y la notification. Usted debe presentar ua
apariencia esrita 0 en persona 0 por abogado y archivar en Ia corte en forma escrita
sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado
que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra
usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la
peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTATE DOCUMENTO A SU ABOGADO
IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEQUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
PO SIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE PA 17013
(800) 990-9108
hard E. F ebum, uire
FREEBURN & HAMILTON
4415 North Front Street
Harrisburg PA 17IlO
(717) 671-1955
LD. #30965
Date: 8/31/04
Attorney for Plaintiff
JAMES B. FARROW AND
HEATHER FARROW,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. ()J.I - 44Jb
Cl'u~( 'I-~
VALERIE FETTER
CIVIL ACTION - LAW
Defendant
COMPLAINT
AND NOW come Plaintiffs, James B. Farrow and his wife, Heather Farrow, by
their attorneys, Freeburn & Hamilton, and me the following Complaint:
1. Plaintiffs, James B. Farrow and his wife, Heather Farrow, are adult
individuals who reside at 32 Jefferson Street, Duncannon, Perry County,
Pennsylvania.
2. Defendant, Valerie Fetter, is an adult individual who resides at 242 E.
King Street, Shippensburg, Cumberland County, Pennsylvania.
3. The facts and occurrences hereinafter related took place on or about
December 9, 2002 at approximately 10:35 a.m. at the bottom of the SR 81 off-ramp at
SR 34, in Cumberland County, Pennsylvania.
4. At or about that time and place, Plaintiff, James B. Farrow, was driving a
tractor trailer, owned by Jacob Richcreek Transportation, and was stopped at a traffic
signal.
5. At or about that time and place, Defendant was traveling down the off-
ramp behind Plaintiff and failed to stop and collided into the rear of Plaintiffs vehicle.
6. The foregoing accident and all of the injuries and damages set forth
hereinafter suffered by Plaintiffs, James B. Farrow and Heather Farrow, are the direct
and proximate result of the negligent, careless, wanton and reckless manner in which
Defendant, Valerie Fetter, operated her motor vehicle as follows:
a. In operating her vehicle at an excessive rate of speed under the
circumstances;
b. In failing to apply her brakes in time to avoid the collision;
c. In negligently applying her brakes;
d, In failing to observe plaintiffs vehicle on the highway;
e. In failing to operate her vehicle in accordance with existing traffic
conditions and traffic controls;
f. In permitting or allowing her vehicle to strike and collide with the
rear of the vehicle operated by plaintiff;
g. In failing to drive at a speed and in the manner that would allow
defendant to stop within the assured clear distance ahead;
h. In failing to keep a reasonable look-out for other vehicles lawfully
on the road; and
1. In operating her vehicle so as to create a dangerous situation for
other vehicle on the roadway.
7. Defendant's conduct, as set forth above, was in violation of the
Pennsylvania Motor Vehicle Code, which is intended to protect persons lawfully on the
highway such as Plaintiff, James B. Farrow, from personal injury, and thus
constitutes negligence per se.
8. Plaintiffs are entitled to recover non-economic damages because plaintiff
was an occupant of a motor vehicle other than a private passenger motor vehicle as
that term is defined in the Pennsylvania Motor Vehicle Financial Responsibility Law.
2
COUNT I
James B. Farrow, Plaintiffv. Valerie Fetter. Defendant
9. Paragraphs 1-8 are incorporated herein by reference thereto.
10. By reason of the aforesaid collision, Plaintiff, James B. Farrow, suffered
painful and severe injuries to his nerves, bones and soft tissues, which include, but
are not limited to, neck and back injuries.
11. By reason of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has suffered a heightened possibility that he will suffer other or
additional injury in the future, and claim is made therefore.
12. The aforesaid collision and injuries suffered by Plaintiff, James B.
Farrow, may have aggravated or been aggravated by an existing infirmity, condition or
disease, resulting in a prolongation or worsening of the injuries and an enhanced risk
of future harm to Plaintiff, and claim is made therefore.
13. By reason of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has been forced to incur liability for reasonable and necessary
medical tests, medical examinations, medical treatment, medications, hospitalizations
and similar expenses in an effort to diagnose his injuries and to restore himself to
health, and claim is made therefore.
14. Plaintiff has not fully recovered from his injuries and it is reasonably
likely that he will incur similar expenses in the future, and claim is made therefore.
3
15. By reason of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has suffered a loss of earnings and earning capacity and is
entitled to recover the value of the time, earnings and employment benefits he has lost
and which he might reasonably have earned in the pursuit of his ordinary calling, and
claim is made therefore.
16. By reason of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has suffered a loss or impairment of future earning capacity, and
claim is made therefore.
17. By reason of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has incurred incidental costs and expenses the exact amount of
which cannot be ascertained at this time, and claim is made therefore.
18. As a result of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has undergone and in the future will undergo great physical and
mental pain and suffering, great inconvenience in carrying out his daily activities, loss
of life's pleasures and enjoyment, and claim is made therefore.
19. As a result of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has been subjected to severe humiliation, embarrassment,
shame, worry and anger.
20. As a result of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has been subjected to severe mental anguish, emotional distress,
nervous shock, fright and horror.
21. As a result of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he will continue to endure great mental anguish, emotional distress,
shame, worry and anger in the future.
4
22. By reason of the aforesaid collision and injuries suffered by Plaintiff,
James B. Farrow, he has been deprived his enjoyment of the pleasures of life.
23. Plaintiff, James B. Farrow, continues to be plagued by persistent pain
and limitation and, therefore, avers that his injuries may be of a permanent nature,
causing residual problems for the remainder of his lifetime, and claim is made
therefore.
24. As a result of the aforesaid accident, Plaintiff, James B. Farrow, he has
suffered a disfigurement, and claim is made therefore.
WHEREFORE, Plaintiff, James B. Farrow, demands judgment in his favor and
against Defendant, Valerie Fetter, in an amount in excess of TWENTY-FIVE
THOUSAND & 00/100 ($25,000.00) DOLLARS, exclusive of interest and costs and in
excess of any jurisdictional amount requiring compulsory arbitration.
COUNTII-LOSSOFCONSORTIUM
Heather Farrow, Plaintiffv. Valerie Fetter. Defendant
25. Paragraphs 1-24 are incorporated herein by reference thereto.
26. As a result of the aforementioned injuries suffered by her husband,
James B. Farrow, Plaintiff, Heather Farrow, has been and may in the future be
deprived of the aid, assistance, comfort, care, companionship, society and consortium
of her husband, all of which will be of great detriment, and claim is made therefore.
5
27. As a result of the aforementioned injuries suffered by her husband,
James B. Farrow, Plaintiff, Heather Farrow, has incurred expenses and/or liability for
the reasonable and necessary medical tests, medical examinations, medical treatment,
medications, hospitalizations and similar expenses in an effort to diagnose his injuries
and to restore him to health, and claim is made therefore.
WHEREFORE, Plaintiff, Heather Farrow, demands judgment in her favor and
against Defendant, Valerie Fetter, in an amount in excess of TWENTY-FIVE
THOUSAND & 00/100 ($25,000.00) DOLLARS, exclusive of interest and costs and in
excess of any jurisdictional amount requiring compulsory arbitration.
Respectfully Submitted,
By:
Richard E. F
LD. No. 30
4415 North Front Street
Harrisburg PA 17110
(717) 671-1955
~
Date: 8/31/04
Counsel for Plaintiffs
6
VERIFICATION
We hereby verify that the statements in the foregoing document
are true and correct. We understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unswom falsification to authorities.
Dated: '-'-d(P-O'-\
n~ --6 ~
JAiJrES B. FARROW
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HeAT~R FARROW
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-04436 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FARROW JAMES B ET AL
VS
FETTER VALERIE
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
FETTER VALERIE
the
, at 1152:00 HOURS, on the 13th day of September, 2004
at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE
DEFENDANT
CARLISLE, PA 17013
by handing to
VALERIE FETTER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
29.60
.00
10.00
.00
57.60
~~~
R. Thomas Kline
09/13/2004
FREEBURN & HAMILTON
Sworn and Subscribed to before
By:
......
me this It ~ day of
J~ .;2t/Ov A.D.
I
Q. 71ub~ AJ.
~thonotary , ~
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Sheriff
JAMES B. FARROW AND
HEATHER FARROW,
IN THE COURT OF COMMON PLEAS
CUMBERL.a,ND COUNTY,
PENNSYLVANIA
Plaintiffs,
No. 04-443Ei Civil Term
v.
VALERIE FETTER,
Civil Action -Law
Defendant.
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the undersigned's appearance on behalf of Defendant Valerie
Fetter only with regard to the above-captioned matter.
Respectfully submitted,
NEALON & GOVER, P.C.
By:
]h~Y~L"
I.D.#: 83882
2411 North Front Street
Harrisburg, PA 17110
717/232 -9900
0lvt\oL
\ \
Date:
CERTIFICATE OF SERVICE
AND NOW, this 1t day of September, 2004, I hereby certify that I have
served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by
depositing a true and correct copy of same in the United States mail, postage prepaid,
addressed to:
Richard E. Freeburn, Esquire
FREEBURN & HAMILTON
4415 North Front Street
Harrisburg, PA 17110
1kLQ~
Michael S. Ferguson, Esquire
NEALON & GOVER, P.C.
2411N. Front Street
Harrisburg, PA 17110
(717) 232-9900
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JAMES B, FARROW AND
HEATHER FARROW,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs,
v.
No. 04-4436 Civil Term
VALERIE FETTER,
Defendant.
Civil Action -Law
: JURY TRIAL DEMANDED
ANSWER TO COMPLAIII,IT
1.
Admitted on information and belief.
2.
Admitted in part. By way of clarification, the defendant resides at
244 East King Street, Shipp,ensburg, Cumberland County,
Pennsylvania.
3.
Admitted.
4.
Admitted on information and belief.
5.
Admitted.
6. -8.
Denied pursuant to Pa. R.C.P. 102B(e).
COUNT I.
James B. Farrow. Plaintiff v, Valerie F4!tter, Defendant
9.
Paragraphs 1-8 are incorporated herein by reference thereto.
10. - 24.
Denied pursuant to Pa. R.C.P. 10291(e).
WHEREFORE, Defendant, Valerie Fetter, demands judgment in her favor and
against the Plaintiffs with costs to be placed upon the Plaintiffs as permitted by law.
COUNT II. - LOSS OF CONSORTIUM
Heather Farrow, Plaintiff v. Valerie Fletter, Defendant
25.
Paragraphs 1-24 are incorporated herein by reference thereto.
26. - 27.
Denied pursuant to Pa. R.C.P. 1029(e).
WHEREFORE, Defendant, Valerie Fetter, demands judgment in her favor and against
the Plaintiffs with costs to be placed upon the Plaintiffs ;as permitted by law.
Respectfully submitted,
NEALON & GOVER, P.C.
1Uc I, f7K5I
By: CRU 067/Jl.-r-
Michael S. Ferguson, Esquire
I.D. No. 83882
2411 North Front Street
Harrisburg, PA 17110
Attorney for Defendant
Date:
co j", r :;J..coY
.
VERIFICATION
I verify that the statements made in the foregoing Answer To Complaint With New
Matter are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities.
~~"O a. t~
Valerie Fetter
Dated:
\O1'1~4-
4
CERTIFICATE OF SERVICIE
AND NOW, this If:- day of October, 2004, I hereby certify that I have served
the foregoing ANSWER TO COMPLAINT on the following by depositing a true and
correct copy of same in the United States mail, postage prepaid, and addressed to:
Richard E. Freeburn, Esquire
FREEBURN & HAMILTON
4415 North Front Street
Harrisburg, PA 17110
Attorney for Plaintiffs
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Michael S. Ferguson, Esquire
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JAMES B. FARROW AND
HEATHER FARROW,
Plaintiffs
IN THE COURT OF CO~MON PEAS
CUMBERLAND COUNT1Y, PEN SYLVANIA
NO. 04-4436 CIVIL TERM
v.
VALERIE FETTER,
Defendant
CIVIL ACTION - LAW
PRAECIPE FOR ENTRY OF APPEARA~g
,
TO THE PROTHONOTARY:
Please enter the undersigned's appearance on behalf of ~he Def ndant, Valerie
Fetter, with regard to the above-captioned matter.
Respectfully submitted,
NEALON, GOVER & PERR~
!
By:
s Y G. Shore, Esq ire
I.D. : 85321
2411 North Front Str~et
Harrisburg, PA 17110
717/232-9900
Date: , 3 bdD_~
/ I
, -,
CERTIFICATE OF SERVICE
AND NOW, this ;$1J. day of March, 2005, I hereby certify that I
the foregoing Praecipe for Entry of Appearance on the following ~y depo iting a true
and correct copy of same in the United States mails, postage prepai~, addre sed to:
Richard E. Freeburn, Esquire
FREEBURN & HAMILTON
4415 North Front Street
Harrisburg, PA 17110
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JAMES B. FARROW AND
HEATHER FARROW,
Plaintiffs
IN THE COURT OF COMI\IION PL AS
CUMBERLAND COUNTY!, PENN YLVANIA
NO. 04-4436 CIVIL TERM!
v.
VALERIE FETTER,
Defendant
CIVIL ACTION - LAW
i
PRAECIPE FOR WITHDRAWAL OF APPEARtNCE
TO THE PROTHONOTARY:
i
Please withdraw the undersigned's appearance on behalflof the efendant,
I
Valerie Fetter, with regard to the above-captioned matter.
Respectfully submitted,
NEALON, GOVER & PERRr
I
,
By:
MelU (f1;;Slf"- _I
Michael S. Fergusoni Esquir
I.D. #; 83882
2411 North Front Street
Harrisburg, PA 171110
717/232-9900 I
!
Date; ~/ul"s
.
.
CERTIFICATE OF SERVICE
AND NOW, this 21\"" day of March, 2005, I hereby certify that I have served the
foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true and
correct copy of same in the United States mail, postage prepaid, adqressed t ;
Richard E. Freeburn, Esquire
FREEBURN & HAMILTON
4415 North Front Street
Harrisburg, PA 17110
squire
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
AS a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
DATE: 08/30/2005
d;CS ~half o~ ~ ~ ,
CASEY SHO~ESQ. ~
Attorney f r DEFENDANT
DEl1-581867 38725 - L 01
LOCATION NAME
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
>>> LOCATION LIST <<<
PAGE:
1
RECORDS REQUESTED
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-3092423872S-C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FARROW
FileNo.
04-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for
ALTERNA TIVR PHYSICAL THERAPY
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: .... SEE A TT ACHED RIDER ....
at The MCS Group Inc ]601 Market Street Suite ROO Philadelphia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate Of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
CASEY SHORE. ESO.
2411 N FRONT ST
HARRISBIJRG.PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
A TTORNEY FOR: Defendant
Date:
AUG 30 .
.{Ju If
L I :J t<Jt'~ C;
" ,
Deputy
Seal of the Court
38725-01
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
ALTERNATIVE PHYSICAL THERAPY
6510 UNION DEPOSIT RD.
HARRISBURG, PA 17111
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to .
any and all records, correspondence to and from the consulting and/or treating'
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject: JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SU10-577972 38725-LOl
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 08/30/2005
CASEY SHORE, ESQ.
Attorney for DEFENDANT
DEll-581868 3 a 725 - L 02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
NOTICE OF INTENT TO SERVE A SUBPORNA TO PRODUCE DOCDMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations]
TO: RICHARD FREEBURN, ESQ., PLAINTIFF COUNSEL
NCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or i~ no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by compl~ting
the attached counsel card and returning same to NCS or by contacting our local
NCS office.
DATE: 08/10/2005
NCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
CC: CASEY SHORE, ESQ.
PATRICIA HOFFMAN
- 04-629
Any questions regarding this matter, contact
THE NCB GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-309242 387:2 5 - C 0 :2
>>> LOCATION LIST <<<
PAGE:
1
LOCATION NAME
RECORDS REQUESTED
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-309242 3872S-C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBEtlAND
FARROW
FileNo.
04-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009,22
TO: Custodian of Records for
DIJNCANNON FAMILY HEAI,TH CTR.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE A TT ACHED RIDER ****
at The MCS Groqp [nc [601 Market Street Suite 800 PhiladeJvhia PA 19103
You may deliver or mail legible copies of the documents or produce lhings 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:
CASEY SHORE. ESO.
24 1 1 N FRONT ST.
HARRISBURG PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY TH COURT:
tvil D' ision
Date:
AUG 30 21ll!i
{)u1' 4. dt1.S
Deputy
Seal of the Court
38725-02
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
DUNCANNON FAMILY HEALTH CTR.
5\0 NEW BLOOMFIELD RD.
DUNCANNON, PA 17020
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to
any and all records, correspondence to and from me consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject: JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SU10-S779743872S-L02
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 08(30(2005
CASEY SHORE, ESQ.
Attorney for DEFENDANT
DEll-581869 3872S-L03
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-vs-
CASE NO: 04-4436
FETTER
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations]
TO: RICHARD FREEBURN, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by compl~ting
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 08/10/2005
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
CC: CASEY SHORE, ESQ.
PATRICIA HOFFMAN
- 04-629
Any questions regarding this matter, contact
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-309242 387:2 5 - CO:2
>>> LOCATION LIST <<<
PAGE:
1
LOCATION NAME
RECORDS REQUESTED
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-3092423872S-C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FARROW
FileNo.
04-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for
HOLY SPIRIT HOSPITAl,
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Group Inc 1601 Market Street Suite ROO Philadelohia. PA ]9103
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 produc:ing 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 c:ompelling you to c:omply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
CASEY SHORE. ESO.
2411 N. FRONT ST.
HARRlSBURG.PA 171]0
TELEPHONE: 12]5) 246-0900
SUPREME COURT ID #:
A TTORNEY FOR: Defendant
Date:
~~.
AlJG 3D 2tei
4/ ;;l.o~,
Deputy
Seal of the Court
38725-03
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HOLY SPIRIT HOSPITAL
503 NORTH 21ST STREET
CAMP HILL, PA 17011
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Entire hospital medical file, including but not limited to any and all records,
correspondence to and from the consulting and/or treating physician, files,
memoranda, handwritten notes, history and physical reports, medication!
prescription records, nurse's notes, doctor's comments, dietary restrictions,
and all patient consent or refusal of treatment, procedures, test, and/or
medication, lab and diagnostic test results, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, diagnosis, care, treatment,
admission, discharge, or emergency care pertaining to:
Dates Requested: up to and including the present.
Suhject : JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SU10-577976 3872S-L03
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OP:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 08/30/2005
CASEY SHORE, ESQ.
Attorney for DEFENDANT
DEll-581870 3872S-L04
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations]
TO: RICHARD FREEBURN, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by completing
the attached counsel card and returning same to MCS or by contacting our' local
MCS office.
DATE: 08/10/2005
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
CC: CASEY SHORE, ESQ.
PATRICIA HOFFMAN
- 04-629
Any questions regarding this matter, contact
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-309242 38725-C02
>>> LOCATION LIST <<<
PAGE:
1
LOCATION NAME
RECORDS REQUESTED
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-309242 3 B 725 -CO 2
LOCATION NAME
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
>>> LOCATION LIST <<<
PAGE:
1
RECORDS REQUESTED
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-309242 387:2 5 - C 0 :2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FARROW
FileNo.
04-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for
HOLY SPIRIT HOSPIT AI.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Groun Inc 1601 Market Street Suite 800 Philadelnhia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
CASEY SHORE. ESO.
2411 N. FRONT ST.
HARRISBURG.;PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ill #:
ATTORNEY FOR: Defendant
ivision
P
Date:
AIlG lD 2DI5
f) '4' 4, J.C>DS
Deputy
Seal of the Court
38725-04
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HOLY SPIRIT HOSPITAL
503 NORTH 21ST STREET
CAMP HILL, PA 17011
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Any and all x-ray films and reports, including any and all such items as may
be stored in a computer database or otherwise in electronic forni,
pertaining to:
Dates Requested: up to and including the present.
Subject: JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SUlO-577978 3872S-L04
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OP:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 08/30/2005
CASEY SHORE, ESQ.
Attorney for DEFENDANT
DEll-581871 3872S-LOS
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOC\JMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations I
TO: RICHARD FREEBURN, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by compl~ting
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 08/10/2005
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
ce: CASEY SHORE, ESQ.
PATRICIA HOFFMAN
- 04-629
Any questions regarding this matter, contact
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-30924238725-C02
LOCATION NAME
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
>>> LOCATION LIST <<<
PAGE:
1
RECORDS REQUESTED
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-30924238725-C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FARROW
FileNo.
04-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for
TRISTAN ASSOCIATES
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Graun Ine 160J Market Street Suite 800 Philadelnhia PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:
ADDRESS:
CASEY SHORE. ESO.
2411 N FRONT ST.
HARRISBURG PA 17IlO
TELEPHONE: 12 15) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Pr
Date:
(}I.l 9 .
AIIG 39m
1../ J..CD.S
,
Deputy
Seal of the Court
38725-05
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
TRISTAN ASSOCIATES
2808 OLD POST ROAD
SUITE 100
HARRISBURG, PA 17110
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic fIle, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians, fIles, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
fIlms and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject: JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SUIO-577980 387:2 5 - LOS
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OP:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 08/30/2005
CASEY SHORE, ESQ.
Attorney for DEFENDANT
DEll-581872 3872S-L06
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-VS-
CASE NO: 04-4436
FETTER
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations I
TO: RICHARD FREEBURN, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense hy completing
the attached counsel card and returning same to MCS or by contacting our' local
MCS office.
DATE: 08/10/2005
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
CC: CASEY SHORE, ESQ.
PATRICIA HOFFMAN
- 04-629
Any questions regarding this matter, contact
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-309242 387:2 5 - C 0:2
>>> LOCATION LIST <<<
PAGE:
1
LOCATION NAME
RECORDS REQUESTED
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-3092423872S-C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FARROW
FileNo.
04-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for
HERSHEY MEDICAl, CENTER
(Name of Person or Entity)
Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Group Ine 160] Market Street Suite 800 Philadelphia PA 19103
You may deliver or mail1egible copies of the documents or produce things requested by this subpoena, t6gether
with the certincate 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:
CASEY SHORE. ESO.
241l N FRONT ST
HARRISBURG PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
ision
Date:
{}uq.
AllG 30.
4 ..la(!;$
,
Deputy
Seal of the Court
38725-06
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HERSHEY MEDICAL CENTER
500 UNIVERSITY DRIVE
HERSHEY, PA 17033
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Entire hospital medical me, including but not limited to any and all records,
correSpondence to and from the consulting and/or treating physician, files,
memoranda, handwritten notes, history and physical reports, medication!
prescription records, nurse's notes, doctor's comments, dietary restrictions,
and all patient consent or refusal of treatment, procedures, test, and/or
medication, lab and diagnostic test results, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, diagnosis, care, treatment,
admission, discharge, or emergency care pertaining to:
Dates Requested: up to and including the present.
Subject: JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SUIO-5779823872S-L06
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
COURT OF COMMON PLEAS
PARROW
TERM,
-VS-
CASE NO: 04-4436
PETTER
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 08/30/2005
CASEY SHORE, ESQ.
Attorney for DEFENDANT
DEl1-581873 38725 -LO 7
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-vs-
CASE NO: 04 -443 6
FETTER
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations I
TO: RICHARD FREEBURN, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if no objection is made, then the subpoena may be served. Complete
copies of any reproduced records may be ordered at your expense by compl~ting
the attached counsel card and returning same to MCS or llY contacting our local
MCS office.
DATE: 08/10/2005
MCS on behalf of
C1\.SEY SHORE, ESQ.
Attorney for DEFENDANT
CC: CASEY SHORE, ESQ.
PATRICIA HOFFMAN
- 04 -629
Any questions regarding this matter, contact
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-309242 38725 -CO 2
>>> LOCATION LIST <<<
PAGE:
1
LOCATION NAME
RECORDS REQUESTED
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-309242 38725 - C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FARROW
FileNo.
04-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for
HERSHEY MEDICAL CENTER
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE A TT ACHED RIDER ****
at The MCS Groqp Inc. ]60] Market Street. Suite 800. Philadelnhia PA 19]03
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 FOLLOWD'IG PERSON:
NAME:
ADDRESS:
CASEY SHORE. ESO.
2411 N FRONT ST.
HARRISBURG PA 17110
TELEPHONE: (2] 5) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
{viI vision
Pro
Date:
{Jut{.
AlI6302lJlEj
4 ..;( or~ S-
f
Deputy
Seal of the Court
38725-07
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HERSHEY MEDICAL CENTER
500 UNIVERSITY DRIVE
HERSHEY, PA 17033
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Any and all x-ray films aDd reports, including aDY and all such items as may
be stored in a computer database or otherwise in electronic form,
pertaining to:
Dates Requested: up to and including the present.
Subject: JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SU10-577984 387:2 5 -LO 7
CERTIFICATE
PREREQUISITE TO SERYICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
COURT OF COMMON PLEAS
PARROW
TERM,
-YS-
CASE NO: 04-4436
FETTER
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of
CASEY SHORE, ESQ.
certifies that
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least
twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which
is attached to the notice of intent to serve the subpoena.
MCS on behalf of
DATE: 08(30/200S
CASEY SHORE, ESQ.
Attorney for DEPENDANT
DEll-S8l8H 387:2 5 -LO 8
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN THE MATTER OF:
COURT OF COMMON PLEAS
FARROW
TERM,
-vs-
CASE NO: 04-4436
FETTER
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations I
TO: RICHARD FREEBURN, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, ESQ. intends to serve a subpoena
identical to the one that is attached to this notice. You have twenty (20)
days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If the twenty day notice period is
waived or if. no objection is made, then the subpoena may be served. Comp~ete
copies of any reproduced'records may be ordered at your expense by compl~ting
the attached counsel card and returning same to MCS or 'by contacting our local
MCS office.
DATE: 08/10/2005
IlCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
CC: CASEY SHORE, ESQ.
PATRICIA HOFFMAN
- 04-629
Any questions regarding this matter, contact
THE MCS GROUP INC.
1601 MARKET STREET
'800
PHILADELPHIA, PA 19103
(215) 246-0900
DE:02-309242 387:2 5 -CO:2
", LOCATION LIST <<<
PAGE:
1
LOCATION NAME
RECORDS REQUESTED
ALTERNATIVE PHYSICAL THERAPY
DUNCANNON FAMILY HEALTH CTR.
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
TRISTAN ASSOCIATES
HERSHEY MEDICAL CENTER
HERSHEY MEDICAL CENTER
FIRST CHOICE REHAB SPECIALISTS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X -RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
DE02-30924238725-C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FARROW
File No. __94-4436
vs.
FETTER
SUBPOENA TO PRODUCE DOCUMENTS OR. THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
Custodian of Records for
FIRST CHOICE REHAB SPECIALISTS
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Oronn Ine 1601 Market Street Snite 800 Philadelnhia PA 19103
You may delivet 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:
CASEY SHORE. ESO.
2411 N FRONT ST.
HARRISBlJRG PA 17110
TELEPHONE: (2] 5) 246-0900
SUPREME COURT ill #:
ATTORNEY FOR: Defendant
B~Z'~:OURT:
Pr onotary/C tvil D' sion
Date:
{JU9'
AU6 30211I5
"I .J..CX>S
I
Deputy
Seal of the Court
38725-08
. '
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
FIRST CHOICE REHAB SPECIALISTS
32 WEST SHORT CUT ROAD
NEWPORT, PA 17074
RE: 38725
JAMES FARROW
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billiri~, and diagnostic fIle, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians, fIles, memoranda, handwritten notes, history and physical reports,
medication!prescription records, medical billing and payment records:, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject: JAMES FARROW
32 JEFFERSON ST., DUNCANNON, PA 17020
Social Security #: 190-54-7451
Date of Birth: 02-01-1974
SUlO-5779863872S-L08
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JAMES B. FARROW AND
HEATHER FARROW,
Plaintiffs
v.
VALERIE FETTER
Defendant
TO: Prothonotary
IN THE COU T OF COMMON PLEAS
CUMBERLA D COUNTY, PENNSYLVANIA
NO. 04-4436
CIVIL ACTIO - LAW
PRAECIPE
Kindly mark the above-captioned matter settled d discontinued.
By:
Date: 11/30/06
Respectfully submitted
Richard E. Freeburn, E quire
LD. No. 30965
4415 North Front Stree
Harrisburg, PA 1711 0 '
(717) 671-1955
Attorney for Plaintiffs
I hereby certify that a true and correct copy f the foregoing Praecipe has
been duly selVed on the following this 30th day of ovember, 2006, by placing
the same in the U.S. First Class Mail, postage prepaid, at Harrisburg,
Pennsylvania, addressed as follows:
Dated: 11/30/06
Casey G. Shore, Esquire
NEALON GOVER & PERRY
2411 North Front Street
Harrisburg, PA 17110
BY:
s Assistant to
Richard E. Freebu ,Esquire
Attorney J.D. #3096
FREEBURN & HAM LTON
4415 North Front S eet
Harrisburg, PA 1711 0
(717) 671-1955 !
Attorney for Plaintiffs
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