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Home My WebLink About04-4644 MARY JANE HURRELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2004 . 4644 CIVIL TERM SADIE I. KITNER, Defendant CIVIL ACTION - LAW PRAECIPE TO SETTLE AND DISCONTINUE To Curtis R. Long, Prothonotary: Please mark the above-captioned case settled and discontinued and issue a Settlement Certificate to Marcus A. McKnight, ill, Esquire, at 60 West Pomfret Street, Carlisle, Pennsylvania 17013. Respectfully submitted, IRWIN & McKNIGHT By: 13 Date: 4'N cil~ ~I 4 MARY JANE HURRELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. 2004 - 4644 CIVIL TERM SADIE I. KITNER, Defendant CIVIL ACTION - LA W CERTIFICATE OF SERVICE I, Marcus A. McKnight, ill, Esquire, hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Patricia Hoffman, SCLA ALLSTATE INSURANCE COMPANY Harrisburg Claim Center 6345 Flank Drive, Suite 1000 Harrisburg, PA 1711202765 Jenni Henley Allen, Esq. NEALON GOVER & PERRY 2411 North Front St. Harrisburg, P A 17110 By: , Esquire Date: 4~>+ ).~ 9fJC 7 , (') c s:- (.1'...,. ~;!r eX}) ~( .?; \~ '.. ( ; J::. f~ ..::::~ ::< ~ -...J ~ .:b. :=0 f'\) I\.) -0 .::it: ~ C co ~ ;r nlflJ -om :::09 (~6 ;-:: -, f J~5~ ~,.o D'/1 g """"< (I, MARY JANE HURRELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 2004. <.{(. Y'I CIVIL TERM SADIE A. KITNER, Defendant CIVIL ACTION. LAW PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY, Please issue a Writ of Summons against the defendant, SADIE A. KITNER, and enter my appearance on behalf of the plaintiff, MARY JANE HURRELL. Please direct the Sheriff to serve the defendant as follows: SADIE A. KITNER 133 AMY DRIVE CARLISLE, PA 17013 Respectfully submitted, IRWIN & McKNIGHT By: September 15, 2004 To: SADIE A. KITNER You are hereby notified that Mary Jane Hurrell. plaintiff, has commenced an action against you which you are required to defend or a default judgment may be entered against you, Cu,.:w' R );,<-j' ~. PROtH()NOTARY By: Ch~ {l. ~ DEPUTY Date:~f~ IS' ,2004 ~ ~. ,., f . ~ l.. '" ~ ~ .1: "<.: ~' !'\ ..... '-' C' "1 -...i ,~ v "'\ \ l.,\ ~ C. (",', SHERIFF'S RETURN - REGULAR CASE NO: 2004-04644 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HURRELL MARY JANE VS KITNER SADIE A TREVOR KENT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon KITNER SADIE A the DEFENDANT , at 1120:00 HOURS, on the 23rd day of September, 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to SADIE KITNER a true and attested copy of WRIT OF SUMMONS 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 .00 .00 10.00 ,00 28.00 .~~~ R. Thomas Kline me this 5e::' day of 09/23/2004 MARCUS MCKNIGHT By: ~y~ff Sworn and Subscribed to before (p c.t:;:L..., ,2 mJ i A . D . ~-- ( 1. .~-<- 0. )7uj}", Jar;' r'1>rothonotary , r I MARY JANE HURRELL, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW SADIE A. KITNER, Defendant NO. 2004-4644 CIVIL TERM : JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Sadie A. Kitner, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: t :JJ~ ~hore, Esquire 1.0. #: 8532~1 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: 8 Ja5loc, / I CERTIFICATE OF SERVICE AND NOW, this .).t{Ji:. day of August, 2005, 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 mails. postage prepaid, add~essed to: Marcus A, McKnight, III, Esquire 60 W. Pomfret Street Carlisle, PA 17013 ~"I"ire ~~? N g <-J' ~ (j"J 1'-) UJ ""J -~'::: ~ ~ ;" f:: -Or.q ~')~ ";,~~ ~, '~~f; -'C-1.'i ~;2(S .<~ \11 eJ, ~ ":0 ,< .1.:: -' V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARY JANE HURRELL, Plaintiff SADIE A. KITNER, Defendant NO. 2004-4644 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros, Respectfully submitted, NEALON & GOVER, P.C, Date: -4~cb By: ~ ~ C G, Shore, Esquire 1.1),83521 2411 North Front Street Harrisburg, PA 17110 717/232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros, DATED: /)4 :29, ~ o C. "" >:~ = en ""', c::: I.:.i) f'.) \..':) o ~n '.... :1:" n-Ip -Qrn ~,;_~ C;;l ::::~(~J ":~--::: .:..,~\ (-._D ;~C) c5m ., ).".; CD .< ~, ~ -C'-," .!.:"" -.l MARY JANE HURRELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 2004 . 4644 CIVIL TERM SADIE I. KITNER, Defendant CIVIL ACTION - LAW NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint, order 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 thc court without further money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 Americans with Disabilities Act of 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of ] 990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, 2 MARY JANE HURRELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 2004 . 4644 CIVIL TERM SADIE I. KITNER, Defendant CIVIL ACTION. LAW COMPLAINT AND NOW, this 12th day of December, 2005, come the Plaintiff, MARY JANE HURRELL, by her attorneys, Irwin & McKnight, and makes the following Complaint against the Defendant, SADIE L KITNER: 1. The Plaintiff is Mary Jane Hurrell, an adult individual residing at 7934 Lincoln Way East, Fayetteville, Franklin County, Pennsylvania 17222, 2, The Defendant is Sadie L Kitner an adult individual residing at 133 Amy Drive, Carlisle, Cumberland County, Pennsylvania 17013, 3, On September 20,2002, at approximately 2:30 p,m" the Plaintiff, Mary Jane Hurrell, was operating a 1984 Chevrolet S-1O truck owned by Sherran K. and Joseph Barder, 46 Spring Garden Street, Carlisle, Pennsylvania 17013 on the Harrisburg Pike near the entrance of the US Army War College when she was struck from behind by the Defendant. 3 4, The collision occurred after the Plaintiff, Mary Jane Hurrell, had stopped in a line of traffic at the traffic light located at the entrance to the Army War College, on the 700 block of North Hanover Street, Carlisle, Pennsylvania, The Plaintiff was in the northbound lane of travel waiting to proceed north. 5. The Defendant, Sadie 1. Kitner, was driving a 1992 Chevrolet Corsica which failed to come to a stop at the traffic light and rammed into the rear of the vehicle driven by the Plaintiff. 6, The force of the impact propelled the vehicle driven by the Plaintiff and caused it to hit the rear of the stopped vehicle in front of her. The Plaintiff had engaged her brake lights and was fully stopped when the Defendant struck her. 7, The front of the Defendant's vehicle struck the rear end of the vehicle driven by the Plaintiff causing severe damage to the vehicle. 8, The Plaintiff, Mary Jane Hurrell, suffered severe injuries. She also lost time from her employment sustaining lost wages. 9, The Plaintiff, Mary Jane Hurrell, was taken by ambulance to Carlisle Regional Medical Center, in Carlisle, Pennsylvania, for emergency treatment of her injuries, 4 10, The Defendant, Sadie L Kitner, was cited by the Carlisle Borough Police Department for following too closely to another vehicle in a manner that did not allow her enough time to avoid a collision when traffic stopped, 11. The injuries sustained by the Plaintiffs were caused by the negligence and careless actions of the Defendant, Sadie L Kitner. 12. The Defendant, Said L Kitner, was negligent and careless as follows: a, She failed to maintain her vehicle under proper control in an effort to avoid a collision; b. She was operating her vehicle in an unsafe and careless manner; c, She was not paying attention to traffic on the highway; d. She failed to drive her vehicle at a safe speed; e. She failed to provide any warning of the pending collision to the Plaintiff. f. She was following too closely to another vehicle in a manner that did not allow her enough time to avoid a collision when traffic stopped. ]3, The negligent actions of the Defendant, Sadie I. Kitner, were the proximate cause of the injuries to the Plaintiff, Mary Jane Hurrell. 5 14, The Plaintiff, Mary Jane Hurrell, seeks compensation for the pam and suffering, emotional distress, and loss of life's pleasures since the date of the accident as well as compensation for future losses she will incur in these areas, 15. The Plaintiff, Mary Jane Hurrell, seeks compensation for the medical expenses which she has incurred and may incur in the future to treat her injuries which occurred as a result of the injuries she sustained in the accident. 16, The Plaintiff, Mary Jane Hurrell, also seeks compensation for the serious and permanent injuries she has sustained which has caused extensive pain and suffering as well as lost wages. WHEREFORE, the Plaintiff, Mary Jane Hurrell, requests compensation and damages from the Defendant in the amount in excess of Thirty-Five Thousand and no/100 ($35,000.00) Dollars with interest as permitted by law and the costs of this litigation. Respectfully submitted, IRWIN & MCKNIGHT By: Mareu A. Me , Esquire 60 West Pomfre Stre Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court LD, No, 25476 Attorney for plaintiff Date: December 12, 2005 6 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preraration of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief, I understand that false statements herein made are subject to the penalties of 18 Pa, C,S,A. Section 4904, relating to unsworn falsification to authorities, 71vj1k~4' Date: December 12, 2005 9 MARY JANE HURRELL, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 2004 - 4644 CIVIL TERM SADIE A. KITNER, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Marcus A, McKnight, ill, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Casey G. Shore, Esq, Nealon, Gover & Perry 2411 North Front Street Harrisburg, PA 17110 IRWIN & McKNIGHT By: Marcu A. McKn t, III, Esquire 60 West Pomfret Street Carlisle, P A 17013 (717) 249-2353 Supreme Court LD. No, 25476 Date: December 12, 2005 7 "_..) L r".: , v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARY JANE HURRELL, Plaintiff SADIE A, KITNER, Defendant NO. 2004-4644 CIVIL TERM JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Mary Jane Hurrell c/o Marcus A. McKnight, III, Esquire 60 West Pomfret Street Carlisle, PA 17013 YOU ARE HEREBY NOTIFIED that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission, Respectfully submitted, Date: Jj (v lor,. t NEALON GOVER & PERRY ~~~!:;,~10$1 1.0. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 By: . v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARY JANE HURRELL, Plaintiff SADIE A. KITNER, Defendant NO. 2004-4644 CIVIL TERM JURY TRIAL DEMANDED ANSWER TO COMPLAINT AND NEW MATTER 1-4. Admitted based upon information and belief. 5. Admitted in part; denied in part. It is admitted that the Defendant, Sadie Kitner, was driving a 1992 Chevrolet Corsica at the time of the accident. Any statements regarding the violence of the accident are denied. 6. Admitted in part; denied in part, It is admitted that the vehicle driven by the Plaintiff struck the vehicle in front of her following the contact made by the Defendant's vehicle. The Defendant is without sufficient information to form a belief as to whether the Plaintiff was fully stopped when the Defendant's car struck her. To the extent that an answer is required regarding this averment, it is denied. 7. Admitted in part; denied in part. It is admitted that the Defendant's vehicle came into contact with the vehicle being driven by the Plaintiff. It is specifically denied that the Plaintiff's vehicle suffered severe damage. 8-9. Denied pursuant to Rule 1029(e) of the Pa. R.CP. 10. Admitted. 11-16. Denied pursuant to Rule 1 029(e) of the Pa. R.C.P, WHEREFORE, the Defendant respectfully requests that the Complaint be dismissed with costs to be paid by the Plaintiff. NEW MATTER 17. Paragraphs 1 through 16 are incorporated herein as if reference were made thereto. 18. The Plaintiff's claim may be barred In whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, the Defendant respectfully requests that the Complaint be dismissed with costs to be paid by the Plaintiff. Respectfully submitted, NEALON, GOVER & PERRY By: L' "'../' "'-- 'Ca~~ G. Shore, Esquire I.D. 83521 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: ,Ill JeG., I I . VERIFICATION I, SADIE I. KITNER. verify that the statements made in the foregoing ANSWER TO COMPLAINT AND NEW MATTER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. ,.-., . /- r' ./ .....,L_. , J ," ( ,(..../ .-;>' /. / ./""1' . ~ t,/-' L-' L-< ~ Date' / ~. ') rf ~ {' r/ . . JIt'. ,...t.,. ,,-\_? SiDl~'I.(~N~ 1,' ,. CERTIFICATE OF SERVICE AND NOW, this I J71l day of January, 2006, I hereby certify that I have served the foregoing Answer to Complaint and New Matter on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Marcus A. McKnight, III, Esquire 60 W. Pomfret Street Carlisle, PA 17013 "-- :-;J 'r' ".,'I;_'c' \..;,.~ ;'.' , . -- V. IN THE COURT elF COMMON PLEAS CUMBERLAND CPUNTY, PENNSYLVANIA CIVIL ACTION -Il.AW ; NO. 2004-4644 ~I~IL TERM : JURY TRIAL DE,ANDED MARY JANE HURRELL, Plaintiff SADIE A. KITNER, Defendant PRAECIPE FOR WITHDRAWAL OF AP~EARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on be~alf of the Defendant, Sadie A. ! Kitner, with regards to the above-captioned matter. Respectfully sUbmi1ed, NEALON GOVER ~ PERRY By: se G, h re, Esquire I.D, . 53211 2411 North Front Street Harrisburg, PfA. 17110 717/232-990~ Date: .,,};J-f)oto . .... CERTIFICATE OF SERVIC~ I AND NOW, this ...;z/gl-day of July, 2006, I hereby ctrtify that I have served the foregoing Praecipe for Withdrawal of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: ! i i Marcus A, McKnight, III, Esquire I I 60 W, Pomfret Street i Carlisle, PA 17013 I ~ .. r") '-J -, ' Y"l C" ---l T h1 ~-<) ..1";- :;<-.., -, CF; { ..... MARY JANE HURRELL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND qOUNTY, PENNSYLVANIA : CIVIL ACTION - ~AW V. SADIE A. KITNER, Defendant . ~ NO. 2004-4644 ~jYIL TERM : JURY TRIAL DE~ANDED PRAECIPE FOR ENTRY OF APPEA~NCE j , TO THE PROTHONOTARY: I i Please enter the undersigned's appearance on behrlf of the Defendant, Sadie A. Kitner, with regard to the above-captioned matter, I i Respectfully sUbmi~ed, By: J n nle Allen, Esquire I , '8431~. 2 North rant Street Harrisburg, A 17110 717/232-990 Date: , ~ CERTIFICATE OF SERVIC~ ~ : AND NOW, this ).\ day of July, 2006, I hereby crrtify that I have served the , foregoing Praecipe for Entry of Appearance on the fOllowiH9 by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Marcus A, McKnight, III, Esquire 60 W, Pomfret Street Carlisle, PA 17013 .- .. c..,,_ r :"'0,' --l :.1:: 1"\'1 (y\ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIG/A'AL IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, CUMBERLAND -VS- CASE NO: 2004-4644 SADIE A. KITNER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, 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: 10/18/2006 trCS on behalf of Jil~N,~/2~ Attorney for DEFENDANT R1.20 133-H DEll-0652294 36071-LOl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY JANE HURRELL File No. 2004-4644 vs. SADIE A. KITNER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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 AITACHED RIDER **** at The MCS Group. Ine.. 1601 Market Street Suite 800. Philadelphia. P A 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: JENNI ALLEN. ESO. 2411 NORTH FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant IVlslOn Date: gep+ .?~( ;JD~J., Seal ofthe Court Deputy 36071-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS 246 PARKER STREET CARLISLE. PA 17013 RE: 36071 MARY J HURRELL Prior approval is required 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. Subject : MARY J HURRELL 133 AMY DRIVE, CARLISLE, PA 17013 Social Security #: XXX-XX-6829 Date of Birth: 11-29-1953 Rl.16S 133-H SU10-064606436071-LOl CERTIFICATE PURSUANT TO RULE 4009.22 ORi/G11d A, /. Il\'f~li,; PREREQUISITE TO SERVICE OF A SUBPOENA IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, CUMBERLAND -VS- CASE NO: 2004-4644 SADIE A. KITNER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, 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: 10/18/2006 jslM~lf of J ALLEN, ~, Attorney for DEFENDANT [:~ Rl.20 133-H DEll-0652295 36071-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, -vs- CASE NO: 2004-4644 SADIE A. KITNER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. ALEXANDER SPRING REHAB ALEX T. BOSHNAKOV, M.D. DR. ALLAN J. MIRA DANIEL P. HELY, M.D. MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARCUS MCKNIGHT, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 09/28/2006 MCS on behalf of JENNI ALLEN, ESQ. Attorney for DEFENDANT CC: JENNI ALLEN, ESQ. PATRICIA HOFFMAN - 05-633 - 05-633 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 Rl.16S 133-H DE02-0343047 36071-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY JANE HURRELL File No. 2004-4644 vs. SADIE A. KITNER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL 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 ATTACHED RIDER **** at The MCS Group. Ine 1601 Market Street. Suite 800. Philadelphia P A 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: JENNI ALLEN. ESO. ADDRESS: 2411 NORTH FRONT STREET HARRISBURG. P A 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant ision Date: 5l~pf. ~~, .1.Dd'- Deputy Seal of the Court 36071-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR, RADIOLOGY DEPARTMENT 246 PARKER ST. CARLISLE. PA 17013 RE: 36071 MARY J HURRELL Prior approval is required 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 form, pertaining to: Dates Requested: up to and including the present. Subject : MARY J HURRELL 133 AMY DRIVE, CARLISLE, PA 17013 Social Security #: XXX-XX-6829 Date of Birth: 11-29-1953 Rl.16S 133-H SU10-0646066 36071-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 Ai 11 aIr: IA I,~t t:: II -",,: t ! 'l.JI .... IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, CUMBERLAND -VS- CASE NO: 2004-4644 SADIE A. KITNER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, 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: 10/18/2006 d'], on behalf ~ e J ~,~~I ~ Attorney for DEFENDANT R1.20 133-H DEll-0652296 36071- LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: I R1.16S I MARY JANE HURRELL -VS- SADIE A. KITNER COURT OF COMMON PLEAS TERM, CASE NO: 2004-4644 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. ALEXANDER SPRING REHAB ALEX T. BOSHNAKOV, M.D. DR. ALLAN J. MIRA DANIEL P. HELY, M.D. MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARCUS MCKNIGHT, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 09/28/2006 CC: JENNI ALLEN, ESQ. PATRICIA HOFFMAN MCS on behalf of JENNI ALLEN, ESQ. Attorney for DEFENDANT - 05-633 - 05-633 Any questions regarding this matter, contact 133-H THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-0343047 36071-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY JANE HURRELL File No. 2004-4644 vs. SADIE A. KITNER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEXANDERSPRlNGREHAB (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 IT ACHED RIDER **** at The MCS GrottP.lnc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: JENNI ALLEN. ESO. 2411 NORTH FRONT STREET HARRISBURGr PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: Slpl . ~~. .ADO/" Deputy Seal of the Court 36071-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB 1 TYLER COURT SUITE -200 CARLISLE. PA 17013 RE: 36071 MARY J HURRELL 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 : MARY J HURRELL 133 AMY DRIVE, CARLISLE, PA 17013 Social Security #: XXX-XX-6829 Date of Birth: 11-29-1953 I R1.16S 133-H SU10-064606836071-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ,1 Ole', ; .~ < I' . t,,'? ~ &'. \~r.--.~ ~..- ~...: IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, CUMBERLAND -VS- CASE NO: 2004-4644 SADIE A. KITNER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, 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: 10/18/2006 MCSon behalf of ~ jslJ~~,~1 ~ Attorney for DEFENDANT Rl. 20 133-H DEll-0652297 36071-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, -VS- CASE NO: 2004-4644 SADIE A. KITNER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. ALEXANDER SPRING REHAB ALEX T. BOSHNAKOV, M.D. DR. ALLAN J. MIRA DANIEL P. HELY, M.D. MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARCUS MCKNIGHT, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 09/28/2006 MCS on behalf of JENNI ALLEN, ESQ. Attorney for DEFENDANT CC: JENNI ALLEN, ESQ. PATRICIA HOFFMAN - 05-633 - 05-633 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.16S 133-H DE02-034304736071-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY JANE HURRELL File No. 2004-4644 vs. SADIE A. KITNER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEX T. BOSHNAKOV. M.D. (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 Joe. 1601 Market Street Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to s~k, 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: JENNI ALLEN. ESO. 2411 NORTH FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: j1~- ~~ ). DOL.. I Deputy Seal of the Court 36071-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEX T. BOSHNAKOV. M,D, 220 WILSON STREET SUITE 109 CARLISLE. PA 17013 RE: 36071 MARY J HURRELL 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 : MARY J HURRELL 133 AMY DRIVE, CARLISLE, PA 17013 Social Security #: XXX-XX-6829 Date of Birth: 11-29-1953 Rl.16S 133-H SU10-0646070 36071- L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 . ..I.rl~l'~,' (J,-R., f 1: .' . \1 '~.:,;,. .l'~ " : . ............-; i. I IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, CUMBERLAND -VS- CASE NO: 2004-4644 SADIE A. KITNER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, 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: 10/18/2006 pr~alf of f'. J I ALLEN,~I ~ Attorney for DEFENDANT R1.20 133-H DEll-0652298 36071-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, -VS- CASE NO: 2004-4644 SADIE A. KITNER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. ALEXANDER SPRING REHAB ALEX T. BOSHNAKOV, M.D. DR. ALLAN J. MIRA DANIEL P. HELY, M.D. MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARCUS MCKNIGHT, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 09/28/2006 MCS on behalf of JENNI ALLEN, ESQ. Attorney for DEFENDANT CC: JENNI ALLEN, ESQ. PATRICIA HOFFMAN - 05-633 - 05-633 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.16S 133-H DE02-0343047 36071-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY JANE HURRELL File No. 2004-4644 vs. SADIE A. KITNER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. ALLAN J. MIRA (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 Grol\P. Inc 1601 Market Street. Suite 800. Philadelphia P A 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: JENNI ALLEN. ESO. 2411 NORTH FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: -S'e.pJ, . ~~ ;2DOb I Deputy Seal of the Court 36071-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ALLAN J. MIRA 220 WILSON STREET CARLISLE, PA 17013 RE: 36071 MARY J HURRELL 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 : MARY J HURRELL 133 AMY DRIVE, CARLISLE, PA 17013 Social Security #: XXX-XX-6829 Date of Birth: 11-29-1953 Rl.16S 133-H SU10-0646072 36071- LO 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 '-1~!A J " ff" ..1 ~ J R f (J I . ';"I.L IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, CUMBERLAND -vs- CASE NO: 2004-4644 SADIE A. KITNER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JENNI ALLEN, 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. !siCS on beh,alf of e J~N,~I ~ Attorney for DEFENDANT DATE: 10/18/2006 Rl. 20 133-H DEll-0652299 36071-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS MARY JANE HURRELL TERM, -VS- CASE NO: 2004-4644 SADIE A. KITNER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR CARLISLE REGIONAL MEDICAL CTR. ALEXANDER SPRING REHAB ALEX T. BOSHNAKOV, M.D. DR. ALLAN J. MIRA DANIEL P. HELY, M.D. MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS TO: MARCUS MCKNIGHT, ESQ., PLAINTIFF COUNSEL MCS on behalf of JENNI ALLEN, 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: 09/28/2006 MCS on behalf of JENNI ALLEN, ESQ. Attorney for DEFENDANT CC: JENNI ALLEN, ESQ. PATRICIA HOFFMAN - 05-633 - 05-633 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 Rl.16S 133-H DE02-0343047 36071-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MARY JANE HURRELL File No. 2004-4644 vs. SADIE A. KITNER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DANIEL P. HELY. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc.. 1601 Market Street. Suite 800. Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: JENNI ALLEN. ESO. 2411 NORTH FRONT STREET HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: A TIORNEY FOR: Defendant Date: Skr. d~ I cla'ib Deputy Seal of the Court 36071-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DANIEL P. HELY. M.D. 1 DUNWOODY DRIVE CARLISLE. PA 17013 RE: 36071 MARY J HURRELL 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 : MARY J HURRELL 133 AMY DRIVE, CARLISLE, PA 17013 Social Security #: XXX-XX-6829 Date of Birth: 11-29-1953 Rl.16S 133-H SU10-0646074 36071- L06 () ~.:; ,,' ..~...' ~ ("'''':'> r--:? C,s"'" o c-) --l f'.) o -0 Q :.1..,., - 1--'"" ~F.: :XS,tJ ~~'1 ~ ::r-\ ;~\~ -,- <)J ~ -''''::' [::3 ., C? CO