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HomeMy WebLinkAbout12-2682 f J E { 0 TA ( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, X99" LV' NN t I ' CIVIL DIVISION .:} y1D COUNT' "r NIA Plaintiff(s) & Address(es) PAMELA VOGELSONG and CRAIG VOGELSONG, her husband 114 Laurel Dr. Enola, PA 17025 Case No. 2012- aLQ o o? Civil Term Civil Action -Law Defendant(s) & Address(es) DEBRA SIMMONS 54 Cold Springs Rd. Dillsburg, PA 17019 (see P. 2 for other Defendants) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwarded to Attorney/Sheriff (Please Circle choice) Date : 04/30/2012 °5ignature of Attorney Print Name: Andrew C. Spears, Esq. Address: 1300 Linglestown Rd. Harrisburg, PA 17112 Telephone #: 717-238-2000 Supreme Court ID Number: 87737 • • • • • WRIT OF SUMMONS TO: Debra Simmons, Care Health Systems, Inc.; Care Health Systems, Inc., et al. ??+ S ??o1.7S? ON? C[L ? ,? I (07 O YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. /.I 1Q Prothonotary/Clerk, Civil Division Date: / ?/a?/LGla ?? -- Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION WRIT OF SUMMONS. PAGE 2 Defendants (continued) Care Health Systems, Inc. 1800 Linglestown Rd., Ste. 103 Harrisburg, PA 17110 Care Health Systems, Inc., t/d/b/a Cresscare Medical 103 Mulberry St. Newport, PA 17074 Cresscare Medical, Inc. 1800 Linglestown Rd., Ste. 103 Harrisburg, PA 17110 Cresscare Wellness, Inc. 1820 Linglestown Rd. Harrisburg, PA 17110 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??`ti?tr wt Lr embrr??h? OFFICE OF 'HE SifERIFF Yip P OTHON ' ..'i '. 2012 MAY 24 PM 1: 54 PENNSYLa AN A..,f Pamela Vogelsong I Case Number vs. 2012-2682 Care Health Systems, Inc. (et al.) SHERIFF'S RETURN OF SERVICE 05/02/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Care Health Systems, Inc. t/d/b/a Cresscare Medical, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Writ of Summons according to law. 05/02/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Cresscare Wellness, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Summons according to law. 05/02/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Cresscare Medical, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Summons according to law. 05/02/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Care Health Systems, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Summons according to law. 05/02/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Debra Simmons, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of Summons according to law. 05/04/2012 Perry County Return: And now, May 4, 2012 I, Carl E. Nace, Sheriff of Perrry County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Care Health Systems, Inc. the defendant named in the within Writ of Summons and that I am unable to find them in the County of Dauphin and therefore return same NOT FOUND. Request for service at 103 Mulberry Street, Newport, Pennsylvania 17074 is vacant. 05/08/2012 10:17 AM - Dauphin County Return: And now May 8, 2012 at 1017 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Cresscare Wellness, Inc. by making known unto Pam Beam, Chief Executive Officer for Cresscare Wellness, Inc. at 1820 Linglestown Road, Harrisburg, Pennsylvania 17110 its contents and at the same time handing to her personally the said true and correct copy of the same. 05/08/2012 Dauphin County Return: And now, May 8, 2012 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Care Health Systems, Inc. the defendant named in the within Writ of Summons and that I am unable to find them in the County of Dauphin and therefore return same NOT FOUND. Request for service at 1800 Linglestown Road, Suite 103, Harrisburg, Pennsylvania 17110 the Defendant was not found. 05/08/2012 10:17 AM - Dauphin County Return: And now May 8, 2012 at 1017 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Cresscare Medical, Inc. by making known unto Pam Beam, Chief Executive Officer for Cresscare Medical, Inc. at 1820 Linglestown Road, Harrisburg, Pennsylvania 17110 its contents and at the same time handing to her personally the said true and correct copy of the same. (c) CountySuite Sheriff, Teleosoft. Inc. 05/08/2012 10:01 AM - York County Return: And now May 8, 20121001 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Debra Simmons by making known unto herself personally, at 54 Cold Springs Road, Dillsburg, Pennsylvania 17019 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $119.90 May 22, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Shenff. Teleosoft. Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy, Administration PAMELA VOGELSONG (et al.) Case Number vs. DEBRA SIMMONS 2012-2682 SHERIFF'S RETURN OF SERVICE 05/08/2012 10:01 AM -DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED WRIT OF SUMMONS (WOSM) BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: DEBRA SIMMONS AT 54 COLD SPRINGS ROAD, DILLSBURG, PA 17019. e?- - MICHAEL VAN, DEPUTY SHERIFF COST: $44.09 May 16, 2012 S S S, CHARD P KE EBER, SHERIFF CONMAOMOW&AL VANIA Liz ?Sew ?y Tv*., York County Member, heft E. CO* * MY Public Pyb.1. 2013 Iusocietlon d ufes LA??? Pennsyh NOTARY Affirmed and subscribed to before me this 16TH day of MAY 2012 ic7 CountySwie Sheriff, T"efscsoil Inc. SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania- Perry County Branch No. 2012-2682 Cumberland Co. Pamela & Craig Vogelsong VS Care Health Systems, Inc. 103 Mulberry Street Newport, PA 17074 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit Care Health Systems, Inc., but was unable to locate him/her in his bailiwick. He therefore returns the within Writ of Summons for the above named Defendant(s) Care Health Systems, Inc. at 103 Mulberry Street, Newport, PA 17074. NOT FOUND. PROPERTY IS VACANT. Sincerely, /'r i?? Sworn and subscribed to before me this Wday of , 2012. Carl E. Nace Sheriff of Perry County PENNSYLVANIA JOYS. ZERANCE, NOTARY PUBLIC NEW BLOOMFI LD BQRO., PERRY COUNTY MY COMMISSION EXPIRES MARCH 6, 2014 (Poirit of the ?$hcrff r _f William. T. Tully Solicitor Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PAMELA VOGELSONG AND CRAIG VOGELSONG, HER HUSBAND VS CARE HEALTH SYSTEMS, INC. Sheriff s Return No. 2012-T-1320 OTHER COUNTY NO. 2012-2682 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for CARE HEALTH SYSTEMS, INC. the DEFENDANT named in the within WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, MAY 8, 2012. DEFENDANT IS NO LONGER LOCATED AT ADDRESS: 1800 LINGLESTOWN ROAD, SUITE 103, HARRISBURG, PA 17110 AND HAS NO CONNECTION WITH OTHER DEFENDANTS LISTED ON DOCKET. Sworn and subscribed to before me this 9TH day of May, 2012 -)P*Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Answers, Sheriff of Itn,( By ,//' mss` Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $85.75 5/8/2012 (Atfite of t4e c`*hexiff William, T. Tully Solicitor Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack, Duignan Chef Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PAMELA VOGELSONG AND CRAIG VOGELSONG, HER HUSBAND VS CARE HEALTH SYSTEMS, INC. Sheriff s Return No. 2012-T-1320 OTHER COUNTY NO. 2012-2682 And now: MAY 8, 2012 at 10:17:00 AM served the within WRIT OF SUMMONS upon CRESSCARE MEDICAL, INC. by personally handing to PAM BEAM 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 1820 LINGLESTOWN ROAD HARRISBURG PA 17110 CEO CORRECT ADDRESS FOR SERVICE: 1820 LINGLESTOWN ROAD, HARRISBURG, PA 17110 Sworn and subscribed to before me this 9TH day of May, 2012 1?*2 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17 2014 So Answers, n Sheriff of Uathin,( By i"#f "ve Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $85.75 5/8/2012 .0of . uit of tEj e 'Sl?rxiff William T. Tully Solicitor t® Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack. Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PAMELA VOGELSONG AND CRAIG VOGELSONG, HER HUSBAND VS CARE HEALTH SYSTEMS, INC. Sheriff s Return No. 2012-T-1320 OTHER COUNTY NO. 2012-2682 And now: MAY 8, 2012 at 10:17:00 AM served the within WRIT OF SUMMONS upon CRESSCARE WELLNESS, INC. by personally handing to PAM BEAM 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 1820 LINGLESTOWN ROAD HARRISBURG PA 17110 CEO Sworn and subscribed to before me this 9TH day of May, 2012 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Annsswers,! Sheriff of I? By Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $85.75 5/8/2012 r t+r,J? lfi,,.. 4 r J Andrew C. Spears Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff(s) Fax : (717) 233-3029 E-mail: Spearsaftriaw.com PAMELA VOGELSONG IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) V. NO. 2012-2682 CIVIL ACTION - LAW DEBRA SIMMONS et. al Defendant(s) PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please re-issue the Writ of Summons in the above referenced matter. Please instruct the Sheriff of Cumberland County to serve the Writ upon the defendant Cresscare Medical at the following address: Care Health Systems, Inc. t/d/b/a Cresscare Medical 1531 Commerce Avenue Carlisle, PA 17013 Additionally, please instruct the Sheriff of Cumberland County to deputize the Sheriff of Dauphin County to serve the Writ upon the defendant Care Health Systems, Inc. t/d/b/a Cresscare Medical at the following address: anx? q.7S?d a 124 1 Care Health Systems, Inc. t/d/b/a Cresscare Medical 1820 Linglestown Road Harrisburg, PA 17110 HANDLER, HENNING & ROSENBERG, LLP By - Date- loll Andre L. Spears, Esq. I.D. #87737 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiff r"~' ~'i)-G~~l~ r , ~.._ (= ~~~ ~'FOfiti~3t~0TArZ'r' Andrew C. Spears, Esq. I.D. * 87737 HANDLER, HENNING b ROSENBERG, LLP 1300 Lir~lestcwvn Road, Suite 2 Haniatwr~, PA 17140 Telephone: (747) 238-~0 Fax : (717) 233-31128 E-mail: apearaQhhrlaw.com Zi~IZ ~UJ Lu l~~ (~' I.~I ~~~~~Q~~~ ~(~~~~`~ ~' E N N S Y LVA N I A Attorneys for Plaintiffs PA#~Ei~A VO~sELSONta and CRAG VO~ELSONG, Piainl~Fs v. DEBRA. SIQNS and CARE HEALTH 3'YS`I"EMSs, INC., t/d/b/a CRES$CAIItE MEDICAL, Del~ndants :IN THE COURT OF CC~M+I P4~AS :CUMBERLAND COUNTY, ~NNSYLVANIA :NO. 2012-2682 CIVIL TERM 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 LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE C~ PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE Tp PROV YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 2. Mr. Vogelsong is a competent adult individual and citizen of Pennsylvani currently residing with his wife, Mrs. Vogelsong, at 114 Laurel Drive, Enola, County, Pennsylvania. 3. Ms. Simmons is, upon information and belief, a competent adult individual citizen of Pennsylvania with a last known address of 54 Cold Springs Road, Dillsburg, Y~ County, Pennsylvania. 4. Cresscare is a corporation existing under the laws of the Commonwealth Pennsylvania with a registered business address at 1820 Linglestown Road, Harrisburg, County, Pennsylvania. 5. At all times material hereto, Ms. Simmons was an agent, servant, or employee o: Cresscare and was acting within the scope of said relationship. 6. At all times material hereto, Mrs. Vogelsong was the owner and operator of : 2007 Saturn Ion bearing Pennsylvania registration number GYN4037 ("Mrs. Vogelsong' vehicle") 7. At all times material hereto, Ms. Simmons was the operator of a 2009 T Corolla, owned by her employer, Cresscare, and bearing Pennsylvania registration HCW7427 ("Defendants' vehicle"). 8. At all times material hereto, Mrs. Vogelsong was insured with Erie Company and was covered under the full tort option. 9. At all times material hereto, there were no adverse road or weather conditions. 10. On or about May 27, 2010, Mrs. Vogelsong was lawfully traveling southbound Alexander Spring Road in South Middleton Township, Cumberland County, Pennsylvania. 11. At approximately the same time and place, Ms. Simmons was tra 2 and the traffic upon the highway, in violation of 75 Pa.C.S.A. § 3361; (g) in failing to operate Defendants' vehicle at a speed that was safe under the circumstances, in violation of 75 Pa.C.S.A. § 3361; (h) in failing to keep a reasonable lookout for vehicular traffic; (i) in failing to properly and adequately observe the traffic conditions then and there existing; (j) in operating a motor vehicle inattentively; and (k) in failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have Defendants' vehicle under such control that injury to persons or property could be avoided. 17. As a direct and proximate result of Ms. Simmons' negligence, Mrs. V has: (a) suffered injuries including, but not limited to, back and neck injuries; (b) undergone continuing medical care and surgery for her injuries; (c) required continuing medical treatment, and will need to continue medical treatment indefinitely; (d) been unable to work and will continue to suffer a loss of income and/or earning capacity in the future; (e) suffered physical pain, discomfort, and mental anguish, and will continue to endure the same for an indefinite period of time in the 4 ' fi future, to her physical, emotional, and financial detriment and loss; (f) been compelled, in an effort to cure her injuries, to spend money for medicine and/or medical attention, and will be required to spend money for the same purposes in the future, to her detriment and loss; (g) suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her detriment and loss; and (h) been, and will be, hindered from attending to her daily duties and chores, to her detriment, loss, humiliation, and embarrassment. WHEREFORE, Plaintiff, Pamela Vogelsong, seeks damages from Defendant, Simmons, in an amount in excess of the compulsory arbitration limits of Cumberland County exclusive of interest and costs. COUNT II -VICARIOUS LIABILITY Pamela Vogelsong v. Care Health Systems, Inc., t/d/b/a Cresscare Medical 18. All prior paragraphs are incorporated herein as if set forth fully below. 19. At all times material to this action, Ms. Simmons was an agent, servant, employee of Cresscare. 20. The occurrence of the aforementioned collision and all of the resultant injuries Mrs. Vogelsong are the direct and proximate result of the negligence of Cresscare' agent/servant/employee, Ms. Simmons. 21. The aforementioned negligent conduct of Ms. Simmons occurred while acting and upon, the business of Cresscare and within the course and scope of her relationship with said defendant. 22. The occurrence of the aforementioned collision and all the resultant injuries 5 r _. ~ __ __ Mrs. Vogelsong are the direct and proximate result of the negligence of Ms. Simmons, and more specifically as set forth below: (a) in driving Defendants' vehicle in careless disregard for the safety of persons or property, in violation of 75 Pa.C.S.A. § 3714; (b) in failing to exercise reasonable care in the operation and control. of Defendants' vehicle, in violation of 75 Pa.C.S.A. § 3714; (c) in following another vehicle more closely than was reasonable and prudent, in violation of 75 Pa.C.S.A. § 3310(a); (d) in failing to properly regulate the speed of Defendants' vehicle so as to prevent arear-end collision; (e) in failing to operate Defendants' vehicle at a speed and under such control as to be able to stop within the assured clear distance ahead, in violation of 75 Pa.C.S.A § 3361; (f) in disregarding the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa.C.S.A. § 3361; (g) in failing to operate Defendants' vehicle at a speed that was safe under the circumstances, in violation of 75 Pa.C.S.A. § 3361; (h) in failing to keep a reasonable lookout for vehicular traffic; (i) in failing to properly and adequately observe the traffic conditions then and there existing; (j) in operating a motor vehicle inattentively; and (k) in failing to be continuously alert, in failing to perceive any 6 warning of danger that was reasonably likely to exist, and in failing to have Defendants' vehicle under such control that injury to persons or property could be avoided. 23. As a direct and proximate result of Ms. Simmons' negligence, Mrs. Vogelsong has: (a) suffered injuries including, but not limited to, back and neck injuries; (b) undergone continuing medical care and surgery for her injuries; (c) required continuing medical treatment, and will need to continue medical treatment indefinitely; (d) been unable to work and will continue to suffer a loss of income and/or earning capacity in the future; (e) suffered physical pain, discomfort, and mental anguish, and will continue to endure the same for an indefinite period of time in the future, to her physical, emotional, and financial detriment and loss; (f) been compelled, in an effort to cure her injuries, to spend money for medicine and/or medical attention, and will be required to spend money for the same purposes in the future, to her detriment and loss; (g) suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her detriment and loss; and (h) been, and will be, hindered from attending to her daily duties and chores, to her detriment, loss, humiliation, and embarrassment. WHEREFORE, Plaintiff, Pamela Vogelsong, seeks damages from Defendant, C 7 Health Systems, Inc., t/d/b/a Cresscaze Medical, in an amount in excess of the azbitration limits of Cumberland County, exclusive of interest and costs. COUNT III -LOSS OF CONSORTIUM Craig Vogelsong v. Debra Simmons 24. All prior paragraphs are incorporated herein as if set forth fully below. 25. At all times material hereto, Mr. and Mrs. Vogelsong were lawfully marred man and wife. 26. As a direct and proximate result Ms. Simmons' negligence, Mr. Vogelsong suffered a loss of consortium, society, and comfort from his wife, Mrs. Vogelsong, and he continue to suffer a similar loss in the future. 27. As a direct and proximate result of Ms. Simmons' negligence, Mr. Vogelsong h been compelled, in order to effect a cure for his wife's injuries, to expend money for medici and medical attention and he will be required to expend money for the same purposes in future, to his detriment and loss. WHEREFORE, Plaintiff, Craig Vogelsong, seeks damages from Defendant, De Simmons, in an amount in excess of the compulsory arbitration limits of Cumberland County. exclusive of interest and costs. COUNT III -LOSS OF CONSORTIUM Crain Vogelsong v. Care Health Systems, Inc., t/d/b/a Cresscare M~ie~l 28. All prior paragraphs aze incorporated herein as if set forth fully below. 29. At all times material hereto, Mr. and Mrs. Vogelsong were lawfully married man and wife. 30. As a direct and proximate result of Cresscaze's negligence, Mr. Vogelsong suffered a loss of consortium, society, and comfort from his wife, Mrs. Vogelsong, and he 8 T ~, _ _ continue to suffer a similar loss in the future. 31. As a direct and proximate result of Cresscaze's negligence, Mr. Vogelsong 1 been compelled, in order to effect a cure for his wife's injuries, to expend money for medici and medical attention and he will be required to expend money for the same purposes in t future, to his detriment and loss. WHEREFORE, Plaintiff, Craig Vogelsong, seeks damages from Defendant, Health Systems, Inc., t/d/b/a Cresscaze Medical, in an amount in excess of the comp azbitration limits of Cumberland County, exclusive of interest and costs. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Dated: Aug.', 2012 By: Andre C. peazs (PA 87737) Attorneys for plaintiffs, Pamela & Craig Vogelsong 9 VERIFICATION THE UNDERSIGNED hereby verify that the statements in the foregoing document are based on information that was gathered by counsel in prepazation of this lawsuit. The language of the above-named document is of counsel and not our own. We have read the said document and, to the extent that it is based on information that we to counsel, it is true and correct to the best of our knowledge, information and belief. To the extent that the contents of the said document is that of counsel, we have relied upon our counsel in prepazing this Verification. THE UNDERSIGNED also understand that the statements therein are made subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn falsification to authorities. DATE: l L , ~ `~ ~ AMELA O~ SO G ~,~ ~~ CRAIG VOG LSONG Andrew C. Spears, Esquire I. D.#87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax : (717) 233-3029 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PAMELA VOGELSONG CRAIG VOGELSONG, v. Plaintiffs X10.: 2012-2682 CIVIL TERM DEBRA SIMMONS and CARE HEALTH SYSTEMS, INC., t/d/b/a CRESSCARE MEDICAL, ACTION -LAW Defendants CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served on the Defendants by sending a copy of the same to them as follows: Debra Simmons 54 Cold Springs Rd. Dillsburg, PA 17019 and to Care Health Systems,lnc., t/d/b/a Cresscare Medical 1820 Linglestown Rd. Harrisburg, PA 17110 by United States mail in Harrisburg, Pennsylvania on August, 2012. HANDLER, HENNING & ROSENBERG, LLP DATE: X1,1, ~~.., B Y Andrew .Spears, Esq. I' �:..c 1 1013 JUN li AP!!: Cf'E dfSYD ANIA Andrew C. Spears Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff(s) Fax : (717) 233-3029 E-mail: Spears @hhrlaw.com PAMELA VOGELSONG : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiff(s) v. : NO. 2012-2682 : CIVIL ACTION - LAW CRESSCARE MEDICAL, DEBRA SIMMONS • Defendant(s) PLAINTIFF'S OBJECTION TO SUBPOENA PURSUANT TO RULE 4009.21 Plaintiff, Pamela Vogelsong, objects to the proposed subpoenas that is attached hereto, made a part hereof and marked "Exhibit A," for the following reasons: 1. On or about August 28, 2012, Plaintiff filed a Complaint in the instant matter, alleging personal injuries sustained in an automobile crash. 2. In the Complaint, Plaintiff, Pamela Vogelsong, alleged she sustained injuries including but not limited to her back and neck. 3. On or about May 25, 2013, Plaintiff received Defendants' Notice of Intent to serve a subpoena on Internists of Central PA, R. Lynn Margargle, M.D., Carlisle Regional Medical Center, Holy Spirit Hospital, Hershey Medical Center, Balint Balog, M.D., Richard Evans, D.O., Marcus Keep, MD., Dr. James McInerney, Dr. Christopher Schaiberger, and Central PA Rehab Services Physical Therapy. 4. The Riders to the Subpoenas seek to obtain any and all medical, billing, diagnostic, correspondence or radiology file from each provider, pertaining to Plaintiff, Pamela Vogelsong, from 06/24/1962 to the present. 5. Defendants are clearly entitled to obtain records from Plaintiff's medical providers; however, the time span of the subpoena at issue is unreasonable, as Defendants are seeking records that are over 50 years old. Defendants' subpoenas to Internists of Central PA, R. Lynn Margargle, M.D., Carlisle Regional Medical Center, Holy Spirit Hospital, Hershey Medical Center, Balint Balog, M.D., Richard Evans, D.O., Marcus Keep, MD., Dr. James McInerney, Dr. Christopher Schaiberger, and Central PA Rehab Services Physical Therapy request documents that span an unreasonable time period. 6. Medical, billing, diagnostic, correspondence and radiology records from the Plaintiff's date of birth forward are not reasonably calculated to lead to discovery of admissible evidence and are simply not relevant to the case at bar. WHEREFORE, Plaintiff, Pamela Vogelsong, respectfully requests this Honorable Court issue an Order quashing Defendants' subpoenas of records from Internists of Central PA, R. Lynn Margargle, M.D., Carlisle Regional Medical Center, Holy Spirit Hospital, Hershey Medical Center, Balint Balog, M.D., Richard Evans, D.O., Marcus Keep, MD., Dr. James McInerney, Dr. Christopher Schaiberger, and Central PA Rehab Services Physical Therapy. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Date: June , 2013 By: Andrew . Spears 7) 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Ph.: 717.238.2000 Fax: 717.233.3029 E-mail: spears@hhrlaw.com Attorneys for Plaintiff, Pamela Vogelsong >>> LOCATION LIST «< PAGE: 1 LOCATION NAME RECORDS REQUESTED INTERNISTS OF CENTRAL PA, LTD REC,BILLS,XRAYS, AND PATHOLOGY R. LYNN MAGARGLE, M.D. REC,BILLS,XRAYS, AND PATHOLOGY CARLISLE REGIONAL MEDICAL CTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR BILLING ONLY CARLISLE REGIONAL MEDICAL CTR X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR PATHOLOGY HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL BILLING ONLY HOLY SPIRIT HOSPITAL X-RAY ONLY HOLY SPIRIT HOSPITAL PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY BALINT BALOG, MD REC,BILLS,XRAYS, AND PATHOLOGY RICHARD EVANS, D.O. MEDICAL RECORDS & BILLING MARCUS KEEP, MD. REC,BILLS,XRAYS, AND PATHOLOGY DR. JAMES MCINERNEY REC,BILLS,XRAYS, AND PATHOLOGY DR. CHRISTOPHER SCHAIBERGER REC,BILLS,XRAYS, AND PATHOLOGY CPRS PHYSICAL THERAPY MEDICAL RECORDS & BILLING MCS # 56745-CO1 4 ' °f ' DE02 • COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL : • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for INTERNISTS OF CENTRAL PA. LTD (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: GREGORY E. CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division - JUN 2 0 2013 Date: 51. 3)\ Deputy Seal of the Court 56745-01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL 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: ANDREW C. SPEARS, ESQ. , PLAINTIFF COUNSEL MCS on behalf of GREGORY E. CASSIMATIS, 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: 05/29/2013 MCS on behalf of GREGORY E. CASSIMATIS, ESQ. Attorney for DEFENDANT CC: GREGORY E. CASSIMATIS, ESQ. - THE MCS GROUP INC. ANDREW C. SPEARS, ESQ. 1601 MARKET STREET HANDLER, HENNING, ET AL #800 1300 LINGLESTOWN ROAD PHILADELPHIA, PA 19103 (215) 246-0900 HARRISBURG, PA 17110 MCS # 56745-CO1 DE02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: INTERNISTS OF CENTRAL PA, LTD 108 LOWTHER STREET LEMOYNE, PA 17043 RE: MCS # 56745-L01 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical , billing and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history, and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Including all pathology materials, blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-LO1 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX • File No. 2012-2682 vs. • CRESSCARE MEDICAL, INC., ET AL . • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for R. LYNN MAGARGLE, 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: GREGORY E. CASSIMATIS. ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN 2 0 2013 s f� Date: Deputy Seal of the Court 56745-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: R. LYNN MAGARGLE, M.D. 3335 MARKET STREET CAMP HILL, PA 17011 RE: MCS # 56745-L02 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical , billing and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history, and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Including all pathology materials, blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L02 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • • PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. • CRESSCARE MEDICAL, INC., ET AL . • 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 T - . .. I ,i u. -- • - :11 1' 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: GREGORY E. CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division JUN2 0 12013 Date: 3 t3 Deputy Seal of the Court 56745-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD MEDICAL RECORDS CARLISLE, PA 17015 RE: MCS # 56745-L03 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide the entire hospital medical file, including but not limited to all records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment. This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L03 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX • • File No. 2012-2682 VS. • CRESSCARE MEDICAL, INC., ET AL . • 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 i u re .• I • u. s r-- i - III P il.s-I. i. 'A 1'11 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN 20 013 ,/./ _ c77., � Date: S/c J Deputy Seal of the Court 56745-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD BILLING DPT CARLISLE, PA 17015 RE: MCS # 56745-L04 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L04 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. • CRESSCARE MEDICAL, INC., ET AL : 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.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: GREGORY E. CASSIMATIS, ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JU 20213 Date: S/D3 r Deputy Seal of the Court 56745-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD RADIOLOGY DPT CARLISLE, PA 17013 RE: MCS # 56745-L05 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all x-ray films and reports. This should contain all x-ray films and reports in your possession, all archived x-ray films and reports, or x-ray films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING CT SCANS AND MRI'S Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L05 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • PAMELA VOGELSONG, ET UX • File No. 2012-2682 • vs. • CRESSCARE MEDICAL, INC., ET AL : • 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.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: GREGORY E. CASSIMATIS, ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG,PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: _. dr 1 Prothonotary/Clerk,Civil Division JU 2 0 203 /l •i. _- Date: D3 /13 Deputy Seal of the Court 56745-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD PATHOLOGY DPT CARLISLE, PA 17015 RE: MCS # 56745-L06 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all pathology reports and records. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis care or treatment. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L06 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX • File No. 2012-2682 vs. • • CRESSCARE MEDICAL, INC., ET AL : 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 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG,PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: 'rothonotary/Clerk,Civil Division JUN 0 2 13 Date: S ,D v 12 Deputy Seal of the Court 56745-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL MEDICAL RECORDS 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L07 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide the entire hospital medical file, including but not limited to all records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment. This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L07 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • PAMELA VOGELSONG, ET UX • File No. 2012-2682 • vs. CRESSCARE MEDICAL, INC., ET AL . 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 h- a s a l .l I V I.r - , -- i - :1 1 i ..-I, i. P. 'I I 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG,PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: / �_// Prothonotary/Clerk, Civil Division JU 2 0 N13 � ,, , _ / 1 Date: SJc ' ? Deputy J Seal of the Court 56745-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL BILLING DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L08 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L08 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. • CRESSCARE MEDICAL, INC., ET AL . • 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 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: GREGORY E. CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG, PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN 2 0 2013 1 L f` Date: S)e) i Deputy Seal of the Court 56745-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL RADIOLOGY DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L09 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all x-ray films and reports. This should contain all x-ray films and reports in your possession, all archived x-ray films and reports, or x-ray films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING CT SCANS AND MRI'S Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L09 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • PAMELA VOGELSONG, ET UX File No. 2012-2682 • vs. CRESSCARE MEDICAL, INC., ET AL : • • 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 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG,PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: ' 4Itdf.6.240 Prothonotary/Clerk, Civil Division JUNI2 0 21013 / _ _ 1// Date: S Deputy Seal of the Court Sc7as-in EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL PATHOLOGY DEPARTMENT 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L10 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all pathology reports and records. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis care or treatment. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L10 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX • • File No. 2012-2682 vs. • • CRESSCARE MEDICAL, INC., ET AL : • 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 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: GREGORY E. CASSIMATIS. ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: • Prothonotary/Clerk, Civil Division Date: l 3 Deputy Seal of the Court 56745-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER MEDICAL RECORDS**HU24 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 56745-L11 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide the entire hospital medical file, including but not limited to all records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda , handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment. This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L11 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • PAMELA VOGELSONG, ET UX File No. 2012-2682 • vs. • CRESSCARE MEDICAL, INC., ET AL . • 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 ATTACHED RIDER**** at The MCS Group.Inc.. 1601 Market Street. Suite BQQ,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: GREGORY E. CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: _ s ,_// Prothonotary/Clerk,Civil Division JUN 2 p 201 - �r Date: Z + Deputy Seal of the Court 56745-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER BILLING DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 56745-L12 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L12 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • PAMELA VOGELSONG, ET UX File No. 2012-2682 • vs. • CRESSCARE MEDICAL, INC., ET AL . • 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 ATTACHED RIDER **** at I,- r. . n 1.1 . k- -- i :11 'hil..-l.hi. 1911 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: GREGORY E. CASSIMATIS. ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: _ Defendant BY THE COURT: Prothonotary/Clerk,Civil Division - 41,0 2 22013 Date: / Deputy Seal of the Court 56745-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER RADIOLOGY DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 56745-L13 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all x-ray films and reports. This should contain all x-ray films and reports in your possession, all archived x-ray films and reports, or x-ray films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING CT SCANS AND MRI'S Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L13 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • PAMELA VOGELSONG, ET UX • File No. 2012-2682 vs. CRESSCARE MEDICAL, INC.,ET AL . • 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 ATTACHED RIDER **** at The MCS Group.Inc.. 1601 Market Street.Suite%NI.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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division 3' 2 Deputy Date: /"'' Seal of the Court 56745-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER PATHOLOGY DEPT 500 UNIVERSITY DR. HERSHEY, PA 17033 RE: MCS # 56745-L14 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all pathology reports and records. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis care or treatment. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L14 SU10 • COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • PAMELA VOGELSONG, ET UX • File No. 2012-2682 • vs. • CRESSCARE MEDICAL, INC., ET AL : • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BALINT BALOG, MD (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: GREGORY E. CASSIMATIS, ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG, PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN 201 Date: 13 Deputy Seal of the Court 56745-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BALINT BALOG, MD 3399 TRINDLE ROAD CAMP HILL. PA 17011 RE: MCS # 56745-L15 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical , billing and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history, and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Including all pathology materials, blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L15 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • • PAMELA VOGELSONG, ET UX • File No. 2012-2682 • vs. • CRESSCARE MEDICAL, INC., ET AL . • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RICHARD EVANS. D.O. (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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN 0 201 Date: S cD 3/1 3 Deputy Seal of the Court 56745-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RICHARD EVANS, D.O. 1631 N. FRONT STREET HARRISBURG, PA 17102 RE: MCS # 56745-L16 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Entire medical and billing file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication and prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING PATHOLOGY Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L16 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX • File No. 2012-2682 vs. •• CRESSCARE MEDICAL, INC.,ET AL . • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MARCUS KEEP. MD. (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 801 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: 1 S✓ Prothonotary/Clerk, Civil Division J 0 Deputy Date: 3 Seal of the Court 56745-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MARCUS KEEP, MD. 920 CENTURY DRIVE MECHANICSBURG, PA 17055 RE: MCS # 56745-L17 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical , billing and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history, and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Including all pathology materials, blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L17 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • PAMELA VOGELSONG, ET UX • File No. 2012-2682 vs. • CRESSCARE MEDICAL, INC., ET AL . SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR.JAMES MCINERNEY (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 • .• � It u. :11 ' il.s• ., . '� ' 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: I 1 . _ - Prothonotary/Clerk,Civil Division JU 202013 Qd Date: S k.34 2 Deputy Seal of the Court CI 7AG 10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JAMES MCINERNEY 30 HOPE DRIVE SUITE 1200 HERSHEY, PA 17033 RE: MCS # 56745-L18 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical , billing and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history, and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Including all pathology materials, blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L18 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • PAMELA VOGELSONG, ET UX • File No. 2012-2682 • vs. • CRESSCARE MEDICAL, INC., ET AL : • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS, FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR.CHRISTOPHER SCHAIBERGER (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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: L21L Prothonotary/Clerk, Civil Division JUN 0 20 Date: 5/42//3 Deputy Seal of the Court ct^7,c 1n EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. CHRISTOPHER SCHAIBERGER 30 HOPE DRIVE SUITE 13 HERSHEY, PA 17033 RE: MCS # 56745-L19 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical , billing and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians. Including all files, memoranda, handwritten records and notes, history, and physical reports. Supply all medication and prescription records, medical billing and payment information. Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Including all pathology materials, blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L19 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • PAMELA VOGELSONG, ET UX • File No. 2012-2682 vs. CRESSCARE MEDICAL, INC.,ET AL . • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CPRS 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 ATTACHED RIDER **** at The MCS Group. Inc.. 1901 Market Strect,Suite 800.Philaslelphia.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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division JUMO 201) _ Date: D3// Deputy Seal of the Court 56745-20 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CPRS PHYSICAL THERAPY 3916 TRINDLE ROAD CAMP HILL, PA 17011 RE: MCS # 56745-L20 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Entire medical and billing file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication and prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING PHYSICAL THERAPY RECORDS Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L20 SU10 cop, CUMBERLAND CoUt4T'y Andrew C. Spears Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff(s) Fax : (717) 233-3029 E-mail: Spears @hhrlaw.com PAMELA VOGELSONG IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) V. NO. 2012-2682 CIVIL ACTION - LAW CRESSCARE MEDICAL, DEBRA SIMMONS Defendant(s) PRAECIPE TO WITHDRAW PLAINTIFF'S OBJECTION TO SUBPOENA PURSUANT TO RULE 4009.21 TO THE PROTHONOTARY: Plaintiff, Pamela Vogelsong, by and through her attorneys, HANDLER, HENNING & ROSENBERG, LLP, by Andrew C. Spears, Esq., hereby withdraws her Objection to Subpoena Pursuant to Rule 4009.21, which had been filed with the Court of Common Pleas of Cumberland County, because Plaintiff's counsel and Defendants' counsel have reached a compromise and agreement as to the scope of medical records to be requested. Instead of subpoenaing medical records dating back to 1962, counsel have agreed to a 10-year limit for medical record requests. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Date: l By: Andrew (! Sp> rs Esq. Attorney I.D. # 87 PAMELA VOGELSONG, Plaintiff V. IN THE COURT OF COMMON PLEAS CRESSCARE MEDICAL, DEBRA OF THE NINTH JUDICIAL DISTRICT SIMMONS, Defendants 2012-02682 CIVIL TERM IN RE: PLAINTIFF'S OBJECTION TO SUBPOENA PURSUANT TO RULE 4009.21 ORDER OF COURT AND NOW, this 24th day of June 2013, upon review of Plaintiffs Objection to Subpoena Pursuant to Rule 4009.21, a RULE is issued upon Defendant to show cause why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Rule upon Defendants. Proof of service must be filed prior to the court entertaining a motion to make rule absolute. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey 91P.J. rl.*P -11 Distribution: C= MCC; /Andrew C. Spears, Esq. M- /-,;regory E. Cassimatis, Esq. -<x> ase%10 Ur3 lAenrc%A,5 CD q.0 CD CERTIFICATE ��' j PREREQUISITE TO SERVICE OF A SUBPOENA G,NA/ PURSUANT TO RULE 4009.22 ` IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL i� tv As a prerequisite to service of a subpoena for documents and things suWAt to Rule 4009.22 :Z:M C "1"7-4= �r f"' -C > Z C'7 CD-rf MCS on behalf of GREGORY E. CASSIMATIS, ESQ. A� W certifies that -74 (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: 06/20/2013 GREGO E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-LO1 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL 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: ANDREW C. SPEARS, ESQ. , PLAINTIFF COUNSEL MCS on behalf of GREGORY E. CASSIMATIS, 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: 05/29/2013 MCS on behalf of GREGORY E. CASSIMATIS, ESQ. Attorney for DEFENDANT CC: GREGORY E. CASSIMATIS, ESQ. - THE MCS GROUP INC. ANDREW C. SPEARS, ESQ. 1601 MARKET STREET HANDLER, HENNING, ET AL #800 1300 LINGLESTOWN ROAD PHILADELPHIA, PA 19103 (215) 246-0900 HARRISBURG, PA 17110 MCS # 56745-CO1 DE02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED INTERNISTS OF CENTRAL PA, LTD REC,BILLS,XRAYS, AND PATHOLOGY R. LYNN MAGARGLE, M.D. REC,BILLS,XRAYS, AND PATHOLOGY CARLISLE REGIONAL MEDICAL CTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR BILLING ONLY CARLISLE REGIONAL MEDICAL CTR X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR PATHOLOGY HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL BILLING ONLY HOLY SPIRIT HOSPITAL X-RAY ONLY HOLY SPIRIT HOSPITAL PATHOLOGY HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY HERSHEY MEDICAL CENTER X-RAY ONLY HERSHEY MEDICAL CENTER PATHOLOGY BALINT BALOG, MD REC,BILLS,XRAYS, AND PATHOLOGY RICHARD EVANS, D.O. MEDICAL RECORDS & BILLING MARCUS KEEP, MD. REC,BILLS,XRAYS, AND PATHOLOGY DR. JAMES MCINERNEY REC,BILLS,XRAYS, AND PATHOLOGY DR. CHRISTOPHER SCHAIBERGER REC,BILLS,XRAYS, AND PATHOLOGY CPRS PHYSICAL THERAPY MEDICAL RECORDS & BILLING MCS # 56745-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Custodian of Records for INTERNISTS OF CENTRAL PA LTD (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 snaking 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOU Sl E DRIVE SUITE 103 MECHANICSBURG. _PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT:' -Ito 7_, 1) - 1 1011( JUN 2 0 2013 Prothonotary/Clerk, Civil Division Date: 3 Deputy Seal of the Court 56745-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: INTERNISTS OF CENTRAL PA, LTD 108 LOWTHER STREET LEMOYNE, PA 17043 RE: MCS # 56745-LO1 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical file from 2003 to the present, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Billing - Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-LO1 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 ] GREG CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L02 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG,ET UX : Fite No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for R LYNN MAGARGLE 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$00 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek, in advance,the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GREGORY E.CASSIMATIS,ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 _MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN 2 0 2013 ^� Deputy Date: 13 Seal of the Court 56745-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: R. LYNN MAGARGLE, M.D. 3335 MARKET STREET CAMP HILL, PA 17011 RE: MCS # 56745-L02 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical file from 2003 to the present, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Billing - Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L02 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GfZEGQWE. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L03 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL 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 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: GREGORY E. CASSIMATIS ESQ ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID 4: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division JUN 2 0 013 Date: .S -- '> �3 Deputy Seal of the Court 56745-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD MEDICAL RECORDS CARLISLE, PA 17015 RE: MCS # 56745-L03 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide the entire hospital medical file from 01-01-2003 to the present, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. .Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-LO3 SUM CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGO . CASSIMATIS, ESQ. Attor ey for DEFENDANT MCS # 56745-L04 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIQNAL 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.Inc.. 1601 Market Street,Suite 800 Phill adei hp .a PA 14103 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: GREGORY E.CASSIMATIS, ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE:_(215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: -If, 2UXLL� Prothonotary/Clerk, Civil Division j U N 2 0 313 Deputy Date: sl';) Seal of the Court 56745-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD BILLING DPT CARLISLE, PA 17015 RE: MCS # 56745-L04 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices from 2003 to present. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L04 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGO E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L05 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG,ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL 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.lnc„ 1601 Market Street Suite$00 Rhiladelphia 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: GREGORY E. CASSIMATIS.ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG PA 17055 TELEPHONE:(215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: } Prothonotary/Clerk, Civil Division JUN 13 Deputy Date: Seal of the Court 56745-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD RADIOLOGY DPT CARLISLE, PA 17013 RE: MCS # 56745-LO5 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all x-ray films and reports from 2003 to the present. This should contain all x-ray films and reports in your possession, all archived x-ray films and reports, or x-ray films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING CT SCANS AND MRI'S Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-LO5 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 �' GREGO E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L06 DE11 CQMMQNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Custodian of Records for 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 Inc.- 1601 Market Street,Suite 8g0 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: GREGORY E CASSIMATIS ESO_ ADDRESS: _4999 LOUI E DRIVE SUITE 103 MEC,HANICSBURG, PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID##: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division A 202 013 I Deputy Date: Seal of the Court 56745-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR 361 ALEXANDRIA SPRING RD PATHOLOGY DPT CARLISLE, PA 17015 RE: MCS # 56745-L06 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all pathology reports and records from 2003 to the present. This should contain all pathology records in your possession, all archived records, or records in storage. including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis care or treatment. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L06 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGO E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL 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 800.P,biladelphia.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: GREGORY E. CASSIMATIS., ESQ. ADDRESS: 4999 LOUISE DRIVE _ SUITE 103 MECHANI('SB 7RG,P{k 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: rothonotary/Clerk, Civil Division - JUN 0 2913 Date: v 1 3" Deputy Seal of the Court 56745-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL MEDICAL RECORDS 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L07 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide the entire hospital medical file from 01-01-2003 to the present, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda , handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L07 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGO E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-LO8 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL 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 Groups 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: GREGORY E.CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division -� JU 2Q 013 Deputy Date: Seal of the Court 56745-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL BILLING DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L08 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices from 01-01-2003 to the present. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L08 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 mil, GREGOR . CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L09 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX : File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL 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 ATTACHE12 RIDER **** at The MCS Grob.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: GREGORY E. CASSIMATIS,ESO. ADDRESS: 4999 LOUISE DRIVE _SUITE 103 MECHANI SBURG. PA 17055 TELEPHONE: (215 2) 46.0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN 2 0 2013 'S Date: D Deputy Seal of the Court 56745-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL RADIOLOGY DEPT. 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L09 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all x-ray films and reports from 01-01-2003 to the This shouldcontain all x-ray films and reports in your possession, all archived x-ray films and reports, or x-ray films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING CT SCANS AND MRI'S Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L09 St Il 0 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 . GREGORY E. CASSIMATIS, ESQ. IF Attorney for DEFENDANT MCS # 56745-L10 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL 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 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 parry 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: GREGORY E.CASSIMATIS.ESQ_ ADDRESS: 4999 LOUISE DRIVE SUITE 10.3 MECHANICSBURG, PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division - JU 2 0 13 Date: 1 Deputy Seal of the Court 5F7dS-1 A EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL PATHOLOGY DEPARTMENT 503 N. 21ST STREET CAMP HILL, PA 17011 RE: MCS # 56745-L10 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide any and all pathology reports and records from 01-01-2003 to the present. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis care or treatment. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L10 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 ti GREGORY CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L11 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL 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 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: GREGORY E.CASSIMATIS,ESO._ ADDRESS: 4999 LOUISF DRIVE ATE 103 MECHANICSBURG, PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT:: Ix—ZL Prothonotary/Clerk,Civil Division Date: Deputy Seal of the Court 56745-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER MEDICAL RECORDS**HU24 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 56745-Lll PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide the entire hospital medical file from 01-01.2003 to the present, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospi h , $150,00 for all other providers. MCS # 56745-L.11 SUM CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGO E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L12 DE11 COMMONWEALTH OF PENNSYLVANIA COUNT'OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL 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 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: GREGORY E. CASSIMATIS.ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 10,E _MECHANICSBURG,PA 17055 TELEPHONE:_(215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: _ Defendant BAY THE COURT: `1 � ,� Prothonotary/Clerk,Civil Division JUN P- 201 "60z// Deputy hate: Seal of the Court 56745-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER BILLING DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 56745-L12 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices from 01-01-2003 to the present, This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L12 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 V' �� G EGOIJ E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L13 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG,ET UX File No. 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL 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 ATTACHED RIDER**** at The MCS Group, 1601Mar et Street Suite$00 Philadelphia. PA 1910 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: GREGORY E. CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG, PA 17055 TELEPHONE: (215 -0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: .L Prothonotary/Clerk,Civil Division 2 0 2Q13 Deputy Date; / Seal of the Court 56745-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER RADIOLOGY DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 56745-L13 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all x-ray films and reports from 01-01-2003 to the This shouldcontain all x-ray films and reports in your possession, all archived x-ray films and reports, or x-ray films and reports in storage. Including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING CT SCANS AND MRI'S Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L13 SUN CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGOR CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L14 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL 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 ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800 Philadelphia PA 12103 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: GREGORY E. CASSIMATIS.ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG,PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division �'�, Deputy Date: / Seal of the Court 56745-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER PATHOLOGY DEPT 500 UNIVERSITY DR. HERSHEY, PA 17033 RE: MCS # 56745-L14 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: 210-58-9046 Date of Birth: 06-24-1962 Please provide any and all pathology reports and records from 01-01-2003 to the present. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis care or treatment. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L14 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGOR . CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L15 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BALINT BALOG. MD (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: GREGORY E. CASSIMATIS. ESO. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG, PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THECOURT: 1 s- / jr- Prothonotary/Clerk, Civil Division - - JUN Zoe Date: S ? 3 1 Deputy Seal of the Court 56745-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BALINT BALOG, MD 3399 TRINDLE ROAD CAMP HILL, PA 17011 RE: MCS # 56745-L15 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical file from 2003 to the present, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Billing - Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L15 SUN CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 AREGO� E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L16 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. _ 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RICHARD EVAN. D.O. (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 Ing.. 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: GREGORY E. CASSIMATIS, ESQ. ADDRESS: 4999 LOUISE DRIVE SATE 103 MECH N� ICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: — Defendant BY THE COURT: Prothonotary/Clerk,Civil Division - JUN 0201 Deputy Date: Seal of the Court 56745-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RICHARD EVANS, D.O. 1631 N. FRONT STREET HARRISBURG, PA 17102 RE: MCS # 56745-L16 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Entire medical and billing file from 2003 to present, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication and prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING PATHOLOGY Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L16 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 A4 dR0 E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L17 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 vs. CRESSCARE MEDICAL, INC.,ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MARCUS KEEP. MD (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, Smote 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: GREGORY E. CASSIMATIS.ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE:( 115)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division 0 Deputy Date: Seal of the Court 56745-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MARCUS KEEP, MD. 920 CENTURY DRIVE MECHANICSBURG, PA 17055 RE: MCS # 56745-L17 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical file from 2003 to the present, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Billing - Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs. EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L17 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGO E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L18 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR JAMES MCINERNEY (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the fallowing documents or things: **** SEE ATTACHED RIDER**** at The MCS Croup 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: GREGORY E. CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 _MECHANICSBURG,PA 17055 TELEPHONE: ( 15)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: A 2 0 2913 ProthonotarylClerk,Cwil Division Deputy Date: Seal of the Court c<^r,tr 10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JAMES MCINERNEY 30 HOPE DRIVE SUITE 1200 HERSHEY, PA 17033 RE: MCS # 56745-L18 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical file from 2003 to the present, including but not limited to any and all inpatient and outpatient records. ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Billing - Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans. EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L18 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGORY E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L19 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG,ET UX File No. 2012-2682 V5. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR CHRISTOPHER SCHAIBER tER (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 RIDS**** 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: _GREGORY E.CASSIMATIS,ESQ. ADDRESS: 4999 LOUISE DRIVE SUITE 103 MECHANICSBURG.PA 17055 TELEPHONE: ( 15)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE La-LL Prothonotary/Clerk,Civil Division JVO 20 � Dety Date: pu Seal of the Court C47iC in EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. CHRISTOPHER SCHAIBERGER 30 HOPE DRIVE SUITE 13 HERSHEY, PA 17033 RE: MCS # 56745-L19 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Please provide entire medical file from 2003 to the present, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescriptions records. Billing - Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. Radiology - Provide all diagnostic films and tests, including CAT scans, CT scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology - Including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L19 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS PAMELA VOGELSONG, ET UX TERM, CUMBERLAND -VS- CASE NO: 2012-2682 CRESSCARE MEDICAL, INC. , ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GREGORY E. CASSIMATIS, 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: 06/20/2013 GREGORY E. CASSIMATIS, ESQ. Attorney for DEFENDANT MCS # 56745-L20 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PAMELA VOGELSONG, ET UX File No. 2012-2682 VS. CRESSCARE MEDICAL, INC., ET AL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CPRS 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 ATTACHED RIDER**** at The MCS Groin Inc., 1601 Market Street,Suite 800 Philadelphia. 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: GREGORY E. CASSIMATIS,ESQ. ADDRESS: 4999 LOUPE DRIVE _SUITE 103 MECHANICSBURG. PA 17055 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division JUN tO 201 a Deputy Date: c� Seal of the Court 56745-20 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CPRS PHYSICAL THERAPY 3916 TRINDLE ROAD CAMP HILL, PA 17011 RE: MCS # 56745-L20 PAMELA VOGELSONG 120 REYDNERS ROAD STEELTON, PA Social Security #: XXX-XX-9046 Date of Birth: 06-24-1962 Entire medical and billing file from 2003 to present including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication and prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form. INCLUDING PHYSICAL THERAPY RECORDS Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 56745-L20 SU10 . - s GREGORY E. CASSIMATIS, Esquire Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 ATTORNEY FOR DEFENDANTS PAMELA VOGELSONG and IN THE COURT OF COMMON P .E4 cr CRAIG VOGELSONG, CUMBERLAND COUNTY, `- Plaintiffs PENNSYLVANIAmr-71n 2� 1 r- CD No.2012-2682 > _.4 a V. < ED T� CIVIL ACTION - LAW v © -- DEBRA SIMMONS and CARE HEALTH : >c.:-.: ` ' SYSTEMS, INC. t/d/b/a CRESSCARE : =, MEDICAL, Defendants JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Gregory E. Cassimatis, Esquire certifies that: 1. A notice of intent to serve subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoenas are sought to be served; 2. A copy of the notice of intent, including the proposed subpoenas, is attached to this Certificate; 3. A copy of a letter dated June 19, 2014, and executed by Plaintiff's counsel, Andrew C. Spears, Esquire, indicating no objections and waiver of the Notice of Intent is attached to this Certificate; and 4. The subpoenas which will be served are identical to the subpoenas which are attached to this Certificate. Date: 7-2-/Y By: GregtjE. Cassimatis, Esquire Attorney for Defendants GREGORY E. CASSIMATIS, Esquire Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 ATTORNEY FOR DEFENDANTS PAMELA VOGELSONG anE IN THE COURT OF COMMON PLEAS . CRAIG VOGELSONG, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA No. 2012-2682 v. CIVIL ACTION - LAW DEBRA SIMMONS and CARE HEALTH . SYSTEMS, INC. t/d/b/a CRESSCARE . MEDICAL, Defendants I : JURY TRIAL DEMANDED NOTICE OF INTENT T SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Gregory E. Cassimati! Esquire, counsel for Defendants, Debra Simmons and Care Health Systems, Inc. t/d/b/a Cresscar Medical, intends to serve subpoenas identical to the ones that are kveattached to this notice. You twenty'(20). days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subject subpoenas may bserved. i Date: l By: ');) —7 Gregop . Cassimatis, squire Attorney for Defendants Debra Simmons and Care Health Systems, Inc. t/d/b/a Cresscare Medical GREGORY E. CASSIMATIS, Esquire Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 ATTORNEY FOR DEFENDANTS PAMELA VOGELSONG and : IN THE COURT OF COMMON PLEAS CRAIG VOGELSONG, CUMBERLAND COUNTY, Plaintiffs - PENNSYLVANIA DEBRA SIMMONS and CARE HEALTH SYSLEMS, INC. t/d/b/a CRESSCARE MEDICAL, Defendants No. 2012-2682. . CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: R. Lynn Magargle, MD 3335 Market Street Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents and things from June 1, 2013 to the present pertaining to Pamela Vogelsong, DOB: 6/24/62 ::the entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails. phone messages, history, physical reports, and all prescription records. Billing — please provide any and all billing, insurance claims and payments, outstanding and delinquent invoices. Radiology — provide all diagnostic films and tests, including CT Scans, EEGs, EKGs, EMGs, MRIs and x-rays and all correspondingreports or inventories. Pathology — including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage, including any and all items as may be stored in a computer database or otherwise in electronic form at 4999 Louise Drive, Suite 103, Mechanicsburg, PA 17055. 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 the subpoena may seek a court.order compelling you to comply with it. The subpoena was issued at the request of the following person: Date: ite/f/ Gregory E. Cassimatis, Esquire Attorney I.D. tM 9619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney for Defendants BY THE COURT: (Prothonotary) GREGORY E. CASSIMATIS, Esquire Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 AllORNEY FOR DEFENDANTS PAMELA VOGELSONG and IN THE COURT OF COMMON PLEAS '1 CRAIG VOGELSONG, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA No. 2012-2682 v. CIVIL. ACTION - LAW DEBRA SIMMONS and CARE HEALTH : SYSTEMS, INC. t/d/b/a CRESSCARE MEDICAL, Defendants ...JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Marcus Keep, MD 920 Century Drive Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to •i produce the following documents and things from June 1, 2013 to the present pertaining to Pamela Vogelsong, DOB: 6/24/62: the entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescription records. Billing — please provide any and all billing, insurance claims and_payrnents, outstanding and delinquent invoices. Radiology — provide all diagnostic films and tests, including CT Scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology — including, all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage, including any and all items as may be stored in a computer database or otherwise in electronic form at 4999 Louise Drive, Suite 103, Mechanicsburg, PA 17055. 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 advancethe reasonable cost of preparing the copies or producing the things sought. If you fail to produce thedocuments or things required by this subpoena within twenty (20) days after its service, the party serving the subpoena may seek a court order compelling you to comply with it. The subpoena was issued at the request of the following person: Date: .6, 4, iy Gregory E. Cassimatis, Esquire Attorney ID. #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717)791-0400 Attorney for Defendants BY THE COURT: 1 GREGORY E. CASSIMATIS, Esquire Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 ATTORNEY FOR DEFENDANTS PAMELA VOGELSONG and IN THE COURT OF COMMON PLEAS CRAIG VOGELSONG, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA DEBRA SIMMONS and CARE HEALTH : SYSTEMS, INC. t/d/b/a CRESSCARE MEDICAL, Defendants No. 2012-2682 CIVIL. ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital Medical Records 503 N. 21st Street Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents and things from June 1, 2013 to the present pertaining to Pamela Vogelsong, DOB: 6/24/62: the entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails,phone messages, history, physical reports, and all prescription records. Billing — please provide any and all billing, insurance claims and payments, outstanding and delinquent invoices.. Radiology — provide all diagnostic films and tests, including CT Scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology — including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage, including any and all items as may be stored in a computer database or otherwise in electronic form at 4999 Louise Drive, Suite 103, Mechanicsburg, PA 17055. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together 1 th the certificate of compliance to the party making this request at the the address listed above. You have the right to seek in advance the reasonable cost of preparing co copies or producing the things sought. P P g If you fail to proJuce the documents or things required bythis subpoena within twenty (20) days after its service the party serving the subpoena may seek a court order compelling you to comply with it. The subpoena was issued at the request of the following person: Date: �o Gregory E. Cassimatis, Esquire Attorney I.D. #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney for Defendants ‘viv BY THE COURT: GREGORY E. CASSIMAT1S, Esquire Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 ATTORNEY FOR DEFENDANTS PAMELA VOGELSONG and . IN THE COURT OF COMMON PLEAS CRAIG VOGELSONG, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA DEBRA SIMMONS and CARE HEALTH SYSTEMS, INC. t/d/b/a CRESSCARE MEDICAL,. Defendants No. 2012-2682 CIVIL. ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Hospital Medical Dept. 361 Alexander Spring Carlisle, PA 17015 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents and things from June 1, 2013 to the present pertaining to Pamela Vogelsong, DOB: 6/24/62: the entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescription records. Billing - please provide any and all billing, insurance claims andpavments, outstanding and delinquent invoices. Radiology — provide all diagnostic films and tests, including CT Scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology — including all pathology materials, all blocks, slides, toxicological or pharmacological analyses. and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage, including any and all items as may be stored in a computer database or otherwise in electronic forrn at 4999 Louise Drive, Suite 103, Mechanicsburg, PA 17055. 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 the subpoena may seek a court order compelling you to comply with it. The subpoena was issued at the request of the following person: Date: Gregory E. Cassimatis, Esquire Attorney I.D. #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney for Defendants BY THE COURT: -bad (Prothonotary) GREGORY E. CASSIMATIS, Esquire Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 ATTORNEY FOR DEFENDANTS PAMELA VOGELSONG and IN THE COURT OF COMMON PLEAS CRAIG•VOGELSONG, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA v. DEBRA SIMMONS and CARE HEALTH :. SYSTEMS, INC. t/d/b/a CRESSCARE MEDICAL, Defendants No. 2012-2682 CIVIL ACTION - LAW .. JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:. Steven B. Wolf, MD 3916 Trindle Road Camp Hill; PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents and things pertaining to Pamela Vogelsong, DOB: 06/24-62: the entire medical`file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, •handwritten notes, emails, phone messages, history, physical reports, and all prescription records: Billing — please provide any and all billing, insurance claims and payments, outstanding and delinquent invoices. Radiology — provide all diagnostic films and tests, including CT Scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories.Pathology — including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage, including any and all items as may be stored in a computer database or otherwise in electronic form at 4999 Louise Drive, Suite 103, Mechanicsburg, PA 17055. Youmay 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,failto produce the documents or things required by this subpoena within twenty , (20) days after its service, the party serving the subpoena may seek a court order compelling you to comply with it. The subpoena was issued at the request of the following person: Gregory E. Cassimatis, Esquire Attorney I.D. #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 - Attorney for Defendants BY THE COURT: GREGORY E. CASSIMATIS, Esqu Attorney ID #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 ATTORNEY FOR DEFENDANTS PAMELA VOGELSONG and CRAIG VOGELSONG, Plaintiffs v. • DEBRA SIMMONS and CARE HEA3LTH : SYSTEMS, INC. t/d/b/a CRESSCAR 'E . MEDICAL, Defendants i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2012-2682 CIVIL. ACTION - LAW .. 'JURY TRIAL DEMANDED SUBPOENA TO PRODUC) DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Norman Haueisen, DO Susquehanna Valley Pain M 825 Sir Thomas Court Harrisburg, PA 17109 agement, PC • Within twenty (20) days after ervice of this subpoena, you are ordered by the court to produce the following documents an things pertaining to Pamela Vogelsong, DOB:. 06/24/1962: the entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails, phone messages, history, physical reports, and all prescription records. Billing — please provide any and all billing, insurance claims and payments, outstanding and delinquent invoices. Radiology — provide all diagnostic film s and tests, including CT Scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology — including all pathology materials, all blocks, slide Y toxicological or pharmacological analyses and ;;corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage, including any and all items as may be stored in a computer database or otherwise in electronic form at 4999 Louise Drive, Suite 103, Mechanicsburg,PA 17055. 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 t� 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 the subpoena may seek a court order compelling you .to comply with it. The subpoena was issued at the request of the following person: 'Date: 6//�//� Gregory E. Cassimatis, Esquire Attorney I.D. #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055. (717) 791-0400 - . Attorney for Defendants BY THE COURT: GREGORY E. CASSIMATIS, Esquire ' Attorney ID #49619 4999 Louise Drive, Suite .103 Mechanicsburg, PA 17055 (717) 791-0400 AllORNEY FOR DEFENDANTS PAMELA VOGELSONG and IN THE COURT OF COMMON PLEAS CRAIG VOGELSONG, CUMBERLAND COUNTY, Plaintiffs : PENNSYLVANIA v. DEBRA SIMMONS and CARE HEALTH : SYSIEMS, INC. t/d/b/a CRESSCARE : MEDICAL, Defendants No. 2012-2682 CIVILACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Barry B. Moore Pinnacle Health Neurology 2005 Technology Parkway, Suite 400 Mechanicsburg, PA 17050 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents and things pertaining to Pamela Vogelsong, DOB: 6/24/62: the entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, memoranda, handwritten notes, emails,phone messages, history _physical reports, and all prescription records. Billing — please provide any and all billing, insurance claims and payments, outstanding and delinquent invoices. Radiology — provide all diagnostic films and tests, including CT Scans, EEGs, EKGs, EMGs, MRIs and x-rays and all corresponding reports or inventories. Pathology — including all pathology materials, all blocks, slides, toxicological or pharmacological analyses and corresponding reports. This should contain all records in your possession, all office and admission charts, all archived records, or records in' storage, including any and all items as may be stored in a computer database or otherwise in electronic form at 4999 Louise Drive, Suite 103, Mechanicsburg, PA 17055. 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 the subpoena may seek a court order compelling you to comply with it The subpoena was issued at the request of the following person: Gregory E. Cassimatis, Esquire Attorney I.D. #49619 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney for Defendants BY THE COURT:. CERTIFICATE OF SERVICE AND NOW, this 19 day of Je, 2014, I, Gregory E. Cassimatis, Esquire, Attorney for Defendants, Debra Simmons and Care Health Systems, Inc. t/d/b/a Cresscare Medical, hereby certify that I served a copy of the within Notice of Intent to Serve Subpoenas, by depositing same in the U ited States mail, postage prepaid, in Mechanicsburg, Pennsylvania, addressed to: Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 By: reg. r . Cassimatis, Esquire 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney I.D. # 49619 HARIUSSURC, PA DONMD.M. DrSsEnte GRLGORY E. Gasman AKRON OH Louis M. DEMARco Miiu S'Hum STEPHFN3. CHUMRKOFF JUSTIN k. DUBUKAR JAMES J. REAGAN ATLANTA, GA BERNARDI. KISTLER, JR. JEANNE F. JOHNSON AuxusOM B. BORTN B. BRErrr TERRY AAN D.VESS BFahuNcHAM, AL BRYAN So. s TYM' JENNIFER. T. DENTE? BEITXT.H. PATRICK II C/NCINNP31, OH MARX J. HULLER G. GREGORY LEWIS THOMAS K. MCMACIUN DAVID J. BAI.z No MATTHEW R. SKINNER Kum W. Coswr JOHN K. BEN1N1'ENDI DAVID S. WIRTH' MICHAEL M. NEI -MEW JASON H. MEYER'.' APRIL C. TARVIN DAvm P. BOLERT BRUCE D. KNABE' S1TATEN G. SCHWEULER' CLEVELAND, 011 PATRICK S. CORRIGAN JOHN F. GANNON MOLLY S. HARAAUGH MICHAEL D. FnzrATwnK Krim D. THovus DENNIS G. REHOR ATTO NCH HONsus Max IN =mum Daft 1R.'USS ODIDRIISR WBIGSRP It • GREGORY E. CASSIMATIS ATTORNEY AT LAW'` ' SUITE 103 4999 LIAISE DRIVE MECHANICSBURG,.PA 17055 TELEPHONE (717) 791-0400 FACSIMILE (717) 791-0524 ALL ABOVE ATTORNEYS ARE EMPLOYEES OF THE CINCINNATI INSURANCE COMPANY June 19, 2014 Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Re: Pamela Vogelsong, et. ux. v. Debra Simmons, et. al. Cumberland County CCP No.: 2012-2682 Dear Andrew: COLUMBUS, OH DANIEL G. TAYLOR ALAN E. MAZUR J. RICHARD BRowN DAVID J. HEINLEIN MICHAEL J. MC ANE BEAU IC RYMERs JUSTIN R. KELLEY DAYTON, OH BRIAN R. MCHENRY ROBERT J. JANES MATr1EEw M. SCHMIDT ERIC L DAUBER° EDWARD J. PEDUZZJ DETROIT, MI PAUL J. JOHNSON Roonvr P. HURLEY JILL L ZYSKOwv,u ANDREW C. ELDER. CHRISTOPHER G. DANIELS JASON H. MLYEAL' INDIANArous, IN JON X. SrowELL ASHLEY A. DOROCRE DoucLAs H. FISHER JAMES J. HunoN MINNEAPOUS, MN NAL J. ROBINSON NANCY L GORES EMILY B. UHL TOLEDO, OH SrEPHrN C. ROACI,' BB1AN A. NSIVBERC PAUL R. BONFIcuo NATHAN R. Bon) 'ALSO ...worm IN IN 'Also ADMr!TFn IN KY 'ALSO AWAITED IN MF . 'ALSO ARNA0ITLD IN MS 'A1.S0 ADMrTTEO IN OH ALSO ADMDTPD IN GA t0So ADMErr0p IN SC 'Argo ADMtrr*0 IN FL Enclosed please find a Notice of Intent to Serve Medical Records Subpoenas in the above matter. The subpoenas to be issued to Dr. Steven B. Wolf, Norman Haueisen, DO and Dr. Barry B. Moore are not limited in scope as their records were not previously subpoenaed. The subpoenas directed to R. Lynn Magargle, MD; Marcus Keep, MD; Holy Spirit Hospital and Carlisle Hospital are limited in scope from June 1, 2013 to the present as their records had been previously subpoenaed. When we recently discussed this case, you indicated that you would not object to the issuance of subpoenas and would waive the 20 -days' notice. Accordingly, please sign the bottom of this letter where indicated and return it to my office to confirm your waiver of the 20 -days' notice. Thank you for your assistance in this rnatter and if you should have any questions, please to not hesitate to contact my office. Sincerely, Gregory'E. Cassimatis GEC/kah Enclosures Andrew C. Spears, Esq , Esquire, counsel for Plaintiff have no objection to the serving of subpoenas identified in the attached Notice of Intent and hereby waive the 20 -days' notice. Counsel for Defendant shall provide me with copies of all records they obtain pursuant to the subpoenas. Date: 06/27/14 y - 1 HE ATTORNEYS usTsn ABOVE ARE Nor A PAKENeaSHSP, BuT PRA —nOt TOGETIIE THE CINCINNATI INSURANCE COMPANY FOR THE EXCLUSIVE PURPOSE OF REPRESENTING THE CINCINNATI INSU ILMI LOYED 1:SY CE COM!'ANIES AND THEIR POLICYHOLDERS , Esquire CERTIFICATE OF SERVICE el AND NOW, this day of , 2014, I, Gregory E. Cassimatis, Esquire, Attorney for Defendants, Debra Simmons and Care Health Systems, Inc. t/d/b/a Cresscare Medical, hereby certify that I served a copy of the within Certificate Prerequisite to Service of Subpoenas Pursuant to Rule 4009.22 by depositing same in the United States mail, postage prepaid, in Mechanicsburg, Pennsylvania, addressed to: Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 By: Gre.? E. Cassimatis, Esquire 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney I.D. # 49619