Loading...
HomeMy WebLinkAbout02-0538KIMBERLY SHOPE, a Minor, by LASHELL SHOPE AND RICHARD SHOPE, Her Parents and Natural Guardians, Plaintiffs, Vo RONDELL J. RICE, Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. ~ -...¢'.~00 LAW JURY TRIAL DEMANDED. NOTICE TO DEFEND TO: Rondell J. Rice 1175 Baltimore Road Shippensburg, PA 17257 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, property, or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Associations 2 Liberty Avenue Carlisle, Pa 17013 (717) 249-3166 KIMBERLY SHOPE, a Minor, by LASHELL SHOPE AND RICHARD SHOPE, Her Parents and Natural Guardians, Plaintiffs, RONDELL J. RICE, Defendant. : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CiVli ACTXON NO. : LAW : JURY TRIAL DEMANDED. NOTICE TO DEFEND TO: Rondell J. Rice 1175 Baltimore Road Shippensburg, PA 17257 LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso a notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE 9PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Associations 2 Liberty Avenue Carlisle, Pa 17013 (717) 249-3166 KIMBERLY SHOPE, a Minor, by : LaSHELL A. SHOPE AND RICHARD : SHOPE, Her Parents and Natural Guardians,: : Plaintiffs, : : V. : : RONDELL J. RICE, : : Defendant. : COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. OR.- LAW JURY TRIAL DEMANDED. COMPLAINT 1. Plaintiff Kimberly Shope is a minor who was bom on August 21, 1984. This action is brought on her behalf by LaShell A. Shope and Richard Shope, adult individuals who are the parents and natural guardians ofKimberly Shope. Kimberly Shope, LaShell Shope and Richard Shope reside at 56 Thompson Creek Drive, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant Rondell J. Rice is an adult individual who resides at 1175 Baltimore Road, Shippensburg, Cumberland County, Pennsylvania. 3. On May 28, 2000 Plaintiff Kimberly Shope was a passenger in a motor vehicle being driven by LaShell Shope, which vehicle was being legally operated on Walnut Bottom Road at its intersection with Route 11 in Shippensburg, Cumberland County, Pennsylvania. As LaShell Shope entered the intersection onto Route 11 from Walnut Bottom Road with a green traffic light in her favor, the Defendant suddenly and without warning approached from her left on Route 11, proceeded through a red light, and struck the vehicle driven by LaShell Shope. 4. As a result of the aforesaid accident and collision, Minor Plaintiff Kimberly Shope sustained various personal injuries, all or some of which may be permanent or chronic in nature, including but not limited to, multiple abrasions and contusions in various parts of her body; injuries to her muscles, tendons, ligaments, nerves and other soft tissues; injuries to her neck and shoulders including a paracervical strain and left posterior muscular strain; low back pain, abdominal and pelvic pain, and fluid accumulation in her abdominal and pelvic area; and the development of fibromyalgia. 5. As a result of the aforesaid accident and injuries, Plaintiff has incurred various medical expenses for physicians, hospitals, medical supplies, medications, therapy and other medical treatment, and she may in the future continue to incur such medical expenses. 6. As a result of the aforesaid accident and injuries, Plaintiff has sustained a loss of income and may in the future continue to suffer a loss of income and a permanent impairment of her future earning capacity. 7. As a result of the aforesaid accident and injuries, Plaintiff has undergone emotional and mental distress and anguish, embarrassment and humiliation, and may in the future continue to undergo such mental distress and anguish, embarrassment and humiliation. 8. As a result of the aforesaid accident and injuries, Plaintiff has undergone much pain, suffering, inconvenience, loss of the enjoyment of life, and the loss of life's pleasures and may in the future continue to suffer such losses. 9. As a result of the aforesaid accident and injuries, Plaintiff has sustained scarring and disfigurement. 10. The aforesaid accident and injuries suffered by Minor Plaintiffwere the direct and proximate result of the negligence and carelessness of the Defendant, as follows: a. He failed to stop at a red light; b. He proceeded into the intersection when the traffic signal for him was red, when it was not safe for him to do so, and without yielding the right-of-way to the vehicle drive by LaShell Shope; c. He failed to yield the right-of-way to the vehicle driven by LaShell Shope; d. He failed to keep his vehicle under control; e. He was traveling at an excessive speed; f. He operated his vehicle in such a manner and at such a speed so as to be unable to stop within the assured clear distance ahead; g. He failed to observe the vehicle driven by LaShell Shope; h. He failed to steer or stop his vehicle so as to avoid a collision with the vehicle driven by LaShell Shope; and i. He failed to keep a proper lookout for other vehicles on the roadway, including the vehicle driven by LaShell Shope. 11. Defendant is liable to Minor Plaintiff for all of those damages sustained by Plaintiff, as set for in the preceding paragraphs. WHEREFORE, Plaintiffs demands judgment against Defendant in an amount exceeding that requiring submission to compulsory arbitration, plus costs. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Edward E Knauss, IV I. D. No. 19199 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Dated: VERIFICATION We, LaShell A. Shope and Richard Shope, do hereby verify that the facts set forth in the foregoing Complaint are true and correct to the best of my personal knowledge or information and belief. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: LaShell A. Shope Richard Shope ' SWARTZ, CAMPBELL & DETWEILER BY: KEVIN M. GEARY, ESQUIRE Attorney ID No. 67361 1601 Market Street - 34t~ Floor Philadelphia, Pennsylvania 19103 (215)299-4362 File No.: 0548-80254 Attorney for Defendant, Rondell J. Rice KIMBERLY SHOPE, Minor, by LASHELL SHOPE and RICHARD SHOPE, her parents and natural guardians VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 02-538 RONDELL J. RICE DEFENDANT, RONDELL J. RICE'S ANSWER WITH NEW MATTER TO PLAiNTiFlf~S COMPLAINT Admitted. Denied. Defendant Rondell Pice resides at 56 Furnace Hollow Road, Shippensburg, Cumberland County, pennsylvania. 3. Admitted in part. Denied in part. It is admitted that on May 28, 2002 Plaintiff Kimberly Shope was a passenger is a motor vehicle being driven.by LaShell Shope that was being operated on Walnut Bottom Road at its intersection with Route 11 in Shippensburg, Cumberland County, Pennsylvania. The remainder of the allegations contained in paragraph 3 of Plaintiffs' complaint are denied in that they are conclusions of law to which no responsive pleading is required and/or allegations of fact which, after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained therein. Strict proof of same is demanded at the time of trial. 4. Denied. The allegations contained in paragraph 4 are denied in that after reasonable SWARTZ, CAMPBELL <~ DETWEILER investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained therein. Strict proof of same is demanded at the time of trial. 5. Denied. The allegations contained in paragraph 5 are denied in that after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained therein. Strict proof of same is demanded at the time of trial. 6. Denied. The allegations contained in paragraph 6 are denied in that after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the troth or falsity of the averments contained therein. Strict proof of same is demanded at the time of trial. 7. Denied. The allegations contained in paragraph 7 are denied in that after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained therein. Strict proof of same is demanded at the time of trial. 8. Denied. The allegations contained in paragraph 8 are denied in that after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of the averments contained therein. Strict proof of same is demanded at the time of trial. 9. Denied. The allegations contained in paragraph 9 are denied in that after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the troth or falsity of the averments contained therein. Strict proof of same is demanded at the time of trial. SWARTZ~ CAMPBELL ~ DETWEILER ATTORNEYS AT LAW ' i60I MARKET STREET .34TH FLOOR · pHILADELPHIA. PA 19103-~316 10. Denied. It is specifically denied that Answering Defendant, at any time relevant hereto, was careless, reckless and/or negligent. It is further specifically denied that Answering Failed to stop at a red light; Proceeded into an intersection when the traffic signal was red, when it was not safe for him to do so, without yielding the right of way to the vehicle driven by LaShell Shope; c. Failed to yield the fight of way to the vehicle driver by LaShell Shope; d. Failed to keep his vehicle under control; e. Traveled at an excessive rate of speed; f. Operated his vehicle in such a manner and at such a speed so as to be unable to stop within the assured clear distance; g. Failed to observe the vehicle driven by LaShell Shope; h. Failed to steer or stop his vehicle so as to avoid a collision with the vehicle driven by LaShell Shope; and i. Failed to keep a proper lookout for other vehicles on the roadway, including the vehicle driven by LaShell Shope. Strict proof of same is demanded at the time of trial. 11. Denied. The allegations contained inparagraph 11 of Plaintiff's complaint are denied in that they represent conclusions of law to which no responsive pleading is required. Strict proof of same is demanded at the time of trial. WHEREFORE, Answering Defendant, Rondell J. Rice respectfully requests this Honorable Court enter judgment in his favor and against Plaintiff and dismiss Plaintiff's Complaint with Defendant: a. b. prejudice. 2. Rondell Rice. 3. NEW MATTER Plaintiff's complaint fails to state a cause of action upon which relief may be granted. Plaintiffs' complaint fails to state a cause of action against Answering Defendant, Plaintiffs' complaint is barred and/or limited by the Pennsylvania Comparative Negligence Act, the relevant portions of which are incorporated herein by reference as though same were fully set forth herein at length. 4. Plaintiffwas contributorily negligent as a matter of law. 5. plaintiff knowingly assumed the risk of her injuries. 6. Answering Defendant, Rondell Rice believes and therefore avers that any allegedly negligent acts or omissions were not the proximate cause of Plaintiffs injuries, said negligent acts or omissions being specifically denied. 7. The Plaintiffs claims are barred and/or limited by the applicable statute of limitations, the relevant portions of which are incorporated herein by reference. 8. Plaintiff's injuries and/or damages were caused by their violation of Pennsylvania Rules of the Road, Pa. C.S.A. §3301, et seq. Plaintiff's recovery is barred and/or limited pursuant to the election of the Limited Tort Option. 10. Plaintiff' s injuries, if any, do not fall within the definition of"serious injury" pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Act and Plaintiff is, thus, barred and/or limited from recovery. SWARTZ~ CAMPBELL ~ DETWE~LER ATTORNEY5 AT LAW · 1601 MARKET STREET '34TH FlOOr · PHILADELPHIA, PA 19103-2316 WHEREFORE, Answering Defendant, Rondell Rice respectfully requests that this Honorable Court enter judgment in his favor and against Plaintiff, and dismiss Plaintiff' s Complaint with prejudice. SWARTZ, CAMPBELL & DETWEILER DATE: BY: KEVIN M. GEARY_, Attorney for Defender, Rond¢ll J. Rice SWARTZ~ CAMPBELL ~ DETWEIL£R ATTORNEYS AT LAW · i601 MA~:~KET STREET ,34TH FLOOR · PHILADELPHIA, PA I9103-~316 VERIFICATION The undersigned having read the attached pleading, the undersigned verifies that the within answers are based on information furnished to counsel, which information has been gathered by counsel in the course of this lawsuit. The language of the answers are that of counsel and not of signer. Signer verifies that the within answers are true and correct to the best of the signer's knowledge, information and belief. To the extent that the contents of the answer are that of counsel, verifier has relied upon counsel taking this Verification. This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. I~VIN M. GEAR~IRE SWARTZ, CAMPBELL & DETWEILER BY: KEVIN M. GEARY, ESQUIRE Attorney ID No. 67361 1601 Market Street - 34th Floor Philadelphia, Pennsylvania 19103 (215)299-4362 File No.: 0548-80254 Attorney for Defendant, Rondell J. Rice KIMBERLY SHOPE, Minor, by LASHELL SHOPE and RICHARD SHOPE, her parents and natural guardians VS. RONDELL J. RICE COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 02-538 CERTIFICATE OF SERVICE I, KEVIN M. GEARY, ESQUIRE, attorney for Defendant, Rondell J. Rice, hereby certify that on March 5, 2002, a tree and correct copy of the within Defendant's Answer with New Matter to Plaintiffs Complaint has been served via First Class Mail, Postage Pre-Paid upon all counsel of record address as follows: Edward E. Knauss, IV, Esquire 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 SWARTZ, CAMPBELL & D WEILER Attorney for Defend~__~) Rondell J. Rice DATE: SWARTZ, CAMPBELL & DETWEILER BY: KEVIN M. GEARY, ESQUIRE Attorney ID No. 67361 1601 Market Street - 34th Floor Philadelphia, Pennsylvania 19103 (215)299-4362 Attorney for Defendant, Rondell J. Rice KIMBERLY SHOPE, Minor, by LASHELL SHOPE and RICHARD SHOPE, her parents and natural guardians VS. RONDELL J. RICE COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 02-538 ENTRY OF APPEARANCE WITH JURY TRIAL DEMAND TO THE PROTHONOTARY: Kindly enter my appearance on behalf o£Defendant, Rondeii J. Rice in the above case. Defendant, Rondell J. Rice hereby demands a Jury Trial. Jury of twelve with alternates is demanded. DATE: SWARTZ, CAMPBELL & DETWEILER BY: KEV1N M. GEARY/3~4~1<~ Attorney for Defendant, / ~ Rondell J. Rice ~/ KIMBERLY SHOPE, a Minor, by LaSHELL A. SHOPE AND RICHARD SHOPE, Her Parents and Natural Guardians, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vo RONDELL J. RICE, Plaintiffs, CIVIL ACTION NO. 02-538 CIVIL TERM : : : JURY TRIAL DEMANDED. : Defendant. : REPLY OF PLAINTIFFS TO NEW MATTER 1.-10. All averments in Paragraphs 1 through 10 are denied. WHEREFORE, Plaintiffs demand that the New Matter be dismissed and that judgment be entered in their favor with costs. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ~IV I. D. No. 19199 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs Dated: VERIFICATION We, LaShell A. Shope and Richard Shope, do hereby verify that the facts set forth in the foregoing Complaint are tree and correct to the best of my personal knowledge or information and belief. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: LaShell A. Shope Richard Shope CERTIFICATE OF SERVICE. I, the undersigned, do hereby certify that on the date set forth below, I did serve a tree and correct copy of the foregoing document upon the following person(s) at the following address(es) indicated below by sending same in the United States mail, postage prepaid, as follows: Kevin M. Geary, Esquire Swartz,Campbell & Detweiler 1601 Market Street 34th Floor Philadelphia, PA 19103-2316 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By ~ ~ Dated: KIMBERLY SHOPE, a Minor, by LaSHELL A. SHOPE AND RICHARD SHOPE, Her Parents and Natural Guardians, Plaintiffs, RONDELL J. RICE, Defendant. : COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 02-538 CIVIL TERM JURY TRIAL DEMANDED. CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that on the date set forth below, I did serve a tree and correct copy of the Answers to Defendant's First Set of Interrogator/es 'Directed to Plaintiff, Kimberly Shope, a minor by and through her parents and natural guardians, LaShell Shope and Richard Shope upon the following person(s) at the following address(es) indicated below by sending same in the United States mail, postage prepaid, as follows: Kevin M. Geary, Esquire Swartz,Campbell & Detweiler 1601 Market Street - 34th Floor Philadelphia, PA 19103-2316 METZ~,E,R, WICKERSHAM, KNAUSS & ERB, P.C. Edward E. Knauss, IV I. D. No. 19199 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs Dated: April 1, 2002 KIMBERLY SHOPE, a Minor, by LaSHELL A. SHOPE AND RICHARD SHOPE, Her Parents and Natural Guardians, Plaintiffs, RONDELL J. RICE, Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 02-538 CIVIL TERM JURY TRIAL DEMANDED. CERTIFICATE OF SERVICE I, the undersigned, do hereby certify that on the date set forth below, I did serve a tree and correct copy of the Response to Request for Production upon the following person(s) at the following address(es) indicated below by sending same in the United States mall, postage prepaid, as follows: Kevin M. Geary, Esquire Swartz,Campbell & Detweiler 1601 Market Street - 34th Floor Philadelphia, PA 19103-2316 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. /Edward E. Knauss, IV I. D. No. 19199 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs Dated: March 20, 2002 CERTIFICATE PP~REQ~I~!TE TO SF2',rlCK OF A PURSUAN? TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 eCS on behalf of KEVIN GEARY, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/24/2002 CS om beh~%f of ~3 DEll-328364 8 9 624 --LO 1 C O1-~1~IO MA T .TH OF P E NN S YI~V-~I~I IA COIIb~TY CF IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF COl.fl, lON PLEAS TEI~I, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMI~NTS AND THINGS FOR DISCOVERY PURSU~ TO RULE 4009.21 [ Note: see enclosed list of locations TO: EDWARD E. KNAUSS IV, ESQUIR~ MCS on behalf of KEVlN GEARY, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04104/2002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 SCS on behalf of KEVIN GEARY, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 HARKET STREET ~800 PHILADELPHIA, PA 19103 (21§) 246-0900 DE02-183461 89624--C01 PAGE: 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME MEDICAL RECORDS INSUR~d~CZ MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,RASCHID G ASSOCIATES T%A~LERS INSU~A~CE CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBERLAND VALLEYEMS CHAMBERSBURG IMAGING ASSOC. CUMBERLAND VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES PiS. LAURIE MAYNAKD VALLEY MEDICAL CENTER JOHN C. CAKEY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624--C0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMi3ERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE. & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ORNDORF & RACHID ASSOC. (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 at MCS GROUP INC., 1601 MARKET ST., #800,PHILA.,PA 19103 (Address) 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: KEVIN GEARY, ESQ. ADDRESS: 1601 MARKET ST. PHILA..PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: A~rORNEY FOR: DEFENDANT DATE: BY THE COURT: ,~ Prothonotary/Cl4~k~ Ct{vii Division ~;' / Deputy Seal of the Court (Elf. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORNDORF,RASCHID & ASSOCIATES 761 FIFTH AVE CHAMBERSBURG, PA 17201 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366172 8 9 6 2 4--LO 1 CERTIFICATE PKEP~ZQUiSiTE TO SERVICE OF A 3U~FOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/24/2002 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328365 8 9 624 --LO2 C O lV~l~40 N--~rI~A ! .TH OF PENN S I'I. Vba'~IA IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF C01~ION PLEAS TERM, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2] [ Note: see enclosed list of locations ] TO: EDWARD E. KNAUSS IV, ESQUIRE MCS on behalf of KEVIN GEARY, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning some to MCS or by contacting our local MCS office. DATE: 0410412002 CC: ~%'IN GEARY, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEARY, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET $8oo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624--C01 PAGE: 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME MEDICAL RECORDS I g SL~2~IC E MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE OIh~,.ORF,RASCHID & ASSOCIATES CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBE~VALLEYEMS CHAMBERSBURG IMAGING ASSOC. CUMBERLAND VALLEY HED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURiE MAYNARD VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DEOZ-183461 89624--(~01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOP~ & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.~9 TO: CUSTODIAN OF RECORDS FOR: TRAVELERS INSURANCE CO. (Name of Person or Entity) Within twenty (20) days after service of this su~e~a~t~l~l~rdered by the court to produce the following documents or things: at MCS GROUP INC., 1601 MARKET ST., #800,PI~ILA.,PA 19103 -- (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together w~th the certificate of compliance, to the patty 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: KEVIN GEARY, ESQ. ADDRESS: 1601 MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: A'I'I'O RNEY FOR: DEFENDANT DATE: THE COURT: .- ~ P~thonota~/C~r~Civil Division d / Depu~ Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TRAVELERS INSUREANCE COMPANY P.O: BOX 14385 READING, PA 196123485 RE: 89624 KIMBERLY SHOPE POLICY LGW8037 CLAIM #LWG8037EMR INCLUDING ENTIRE PIP AND PROPERTY DAMAGE FILE. Any and all claims files. sD~a~s Re. quested: up to and including the present. ect. KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366174 8 9 624 --LO 2 CERTIFICATE FP~EIt~QUISITE TO S~VICE OF A .eLr~FCE~t PURSUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/24/2002 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328566 89624--L0 3 C OI"It,~O Nl~ ~--.A ~' -TH OF P g NN S EV~I~I IA COL~Tk~ OF IN THE HATTER OF: KIHBERLY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF CO~ON PLEAS TERH, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPnm~ TO PRODUCE DOCUMENTS T~IINGS FOR DISCOv~R~ PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: EDWARD E. I~IAUSS IV, ESQUIRE MCS on behalf of l~VIN GEARY, EsquiRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~enty (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 HCS or by contacting our local MCS office. DATE: 0410412002 CC: KEVIN GEAKY, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEA~Y, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE HCS GROUP INC. 1601 HAP~ET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624--C01 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAMe. PAGE: 1 MEDICAL RECORDS MEDICAL P. ECOEDS INSUP, ANCE MEDICAL KECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,RASCHID ~ ASSOCIATES TR%*.~-ERS I.WSUPJ~1~C! C0.~2~ CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBERLAND VALLEY EMS CHAMBERSB~IRG IMAGING ASSOC. CUMBE~ VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAUEIE MAYNARD VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624--C01 COMMONWEALTH OF PENNSYLVANIA C©UNTY OF CUMi~ERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE. & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,?? TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG 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 at Iv[CS GROUP tNG., 1601 MARKET ST., #800,PHtLA.,PA 19103 (Address) 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 fall 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: KEVIN GEARY~ ESQ. ADDRESS: 1601 MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CitAMBERSBURG HOSPITAL P.O. BOX 897 CHAMBERSBURG, PA 17201 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366176 89 624--L0 3 CERTIFICATE PREREQUISITE TC SERVICE OF A ZY,~i'0EI~% PURSUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/24/2002 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328367 8 9 624 --LO 4 COlVllVlOl~Vvv'F-~r-TH OF PENNS'~[.Vi~i~iA IN THE HATTER OF: KIHBERLY SHOPE.A HINOR . ET AL -VS- RONDELL J. RICE COURT OF COlOrON PLEAS TERM, CASE NO: 02-538 NOTICE OF IN~El~ ~0 SERVE A SUBPORNa ~0 PRODUCE DOCTOR.S AND THINGS FOR DISCov~K~ PURSUAI~ ~0 RULE 4009.21 [ Note: see enclosed list of locations ] TO: EDWARD E. KNAUSS IV, ESQUIRE HCS on behalf of lul¥-# GEARYt ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~enty (20) days fro~ the date listed belo~ in vhich to file of record and serve upon the undersigned an objection to the subpoena. If the tventy day notice period is vaived 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 returninE same to MCS or by contacting our local MCS office. DATE: 0~10~12002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 MCS on behalf of s,~v~.N Gl~ey~ ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact · £~ HCS GROUP INC. 1601 HARLOT SI~T ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624--C01 LOCATION LIST <<< LOCATION PAGE: H~D ICkL RgCOP. DS HgDICAL KECOP. DS INSURANCE PIgDICAL P, gCOKDS PIgDICAL KECOP. DS HF, DICAL P. gCO1U)S HEDICAL KECOP. DS HF. DICAL I~CORDS HF, DICAL KECOKDS HEDICAL KECOIU)S INSURANCE OIUqDOP~,RASCHID & ASSOCIATES C~ERSB~G HOSPIT~ ~LSTATE INS. CO. C~ V~ ~ C~SB~G ~G~ ~S~. C~ V~ ~. SRVC. ~P~CH~ OR.OPtIC C~ OR~OPEDIC AS$0C~S V~ ~I~ C~ JO~ C. ~, M.D. ~g~ INS~CE C~ DE02-183461 89624--C0~L COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMbEI-~LAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-~ TO: CUSTODIAN OF RECORDS FOR: ALLSTATE INSURANCE (Name of Person or Entity) W;thin twenty (20) days after service of this subpoena,you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800,PHILA.,PA 19103 (Address) You may deliver or mall [egible 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: KEVIN GEARY, ESQ. ADDRESS: 1601 MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court BY THE COURT: r~ , Prothonotary/Clet~x, Civil Div s on / I Deputy (Elf. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALLSTATE INS. CO. 6345 FLANK [)RIVE SUITE 1000 HARRISBURG, PA 17112 RE: 89624 KIMBERLY SHOPE Any and all claims files. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366178 89 624 --LO 4 CERTIFICATE PR~ILEQUISITE TO SERVICE CF A SL~OEIL% PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY SHOPE,A MINOR , ET AL TERM, oVS- CASE NO: 02-538 RONDELL J. RICE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE 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: 04/24/2002 KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328368 89 624--L0 5 C O {~[lVlO N--W -:A T -TH OF P E NN S ~I~V/~lq IA C OIIlqTY CF IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF C0~0N PLEAS TERM, CASE NO: 02-538 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: EDWARD E. K/~AUSS IV, ESQUIRE MCS on behalf of KEVIN GEARY, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the t~enty 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: 04/04/2002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET ~8o0 PMILADELPMIA, PA 19103 (215) 246-0900 DE02-183461 89624--CO 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME MEDICAL KECO Pd) S I N ~ [PR-~NC E MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,KASCHID & ASSOCIATES T?3J~!,ERS INSURZANCU CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBERLAND VALLEY EMS CHAMBEESBURG IMAGING ASSOC. CUMBERLAND VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURIE MAYNARD VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMbEIkLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE. & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-~ TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND VALLEY EMS (Name of Person or Entity) Within twenty (20) days after service of this subpoena you are ordered by the court to produce the following documents or things: SEE A~TACHED at MCS GROUP INC., 1601 MARKET ST., #800,PHILA.,PA 19103 (Address) 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: KEVIN GEARY, ESQ. ADDRESS: 1601 MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court BY THE C, OURT:,~ ProthonotaryjCl'er~4 Civil Division - / I Depu~ (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND VALLEY EMS P.O.' BOX 100 CARLISLE, PA 17013 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366180 89624--L05 CERTIFICATE PP~EKEQUISITE TO S%P.'fICE OF A SL~UCENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY SHOPE,A MINOR , ET AL TERM, -VS- CASE NO: 02-538 RONDELL J. RICE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 eCS on behalf of KEVIN GEARY, ESQUIRE 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. eCS on behalf of DATE: 04/24/2002 KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328369 89624--L06 C 0 [v~v[O 1~1--I~1~A~ T - T H OF IN TEE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF CO['~ION PLEAS TERM, CASE NO: 02-538 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: EDWARD E. KNAUSS IV, ESQUIRE MCS on behalf of KEVIN GEARY, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 0410412002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROU~ INC. 1601 MAKKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624 --CO 1 PAGE: 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,RASCHID & ASSOCIATES CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBERLAND VALLEY EMS CHAMBERSBURG IMAGING ASSOC. CUMBERLAND VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89 624--C0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOP~ & RICHARD SHOPE, HER PARENTS & NATURAL . GUARDIANS RONDELL J. RICE ' File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.?? TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG IMAGING ASSOC. (Name of Person or EnHty) Within twenty (20) days after service of this subpoena, you are ordered by the cour~ to produce the followlng documents or things: SEE ATTACHED - at MCS GROUP INC.. 1601 MARKET ST., #800,PHILA.,PA 19103 (Address) 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 par~ 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: KEVIN GEARY, ESQ. ADDRESS: 1601 MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court BY THE COURT~ Prothonotar~fCl0i~k, Civil Division 1). / / Depu~ (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHAMBERSBURG IMAGING ASSOC. 25 PENNCRAFT AVENUE PROF. ARTS BUILDING CHAMBERSBURG, PA 17201 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366182 89624 --LO 6 CERTIFICATE PREREQUISITE TO 3ZPJZICE OF A SLedGE:iA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY SHOPE,A MINOR , ET AL TERM, -VS- CASE NO: 02-538 RONDELL 3. RICE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE 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: 04/24/2002 KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328370 89 624 --L07 C Ol~ll~[O MA T -TH OF PENN S YI~V~%l~ IA IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF COn, iON PLEAS TERM, CASE NO: 02-538 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: EDWARD E. KNAUSS IV, ESQUIRE MCS on behalf of KEVIN GEARY, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04/0412002 CC; KEVIN GEARY, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEARY, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MJd~%ET STREET S8oo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624 --CO1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME PAGE: 1 MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,RASCHID & ASSOCIATES CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBERLAND VALLEY EMS CHAMBERSBURG IIMAGING ASSOC. CUMBERLAND VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURIEMAYNAiLD VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-~ TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND VALLEY MEDICAL SERVICES (Name of Per, on or EntiVf) Within twenty (20) days after service of this subpoena you are ordered by the court to produce the following documents or thimgs: SE~ ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800,PHILA. ,PA 19103 (Address) 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 fall 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 FOLLOI~ING PERSON: NAME: KEVIN GEARYt ESQ. ADDRESS: 1601 MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATFORNEY FOR: DEFENDANT DATE: Seal of the Court BY THE COURT: Prothonotary/Cl~r~, ~lvil Division / / Deputy (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND VALLEY MED. SRVC. 601 NORLAND AVENUE SUITE 201 CHAMBERSBURG, PA 17201 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366184 89624--L07 CERTIFICATE PFdLREQUISITE TO SERVICE OF A S%~PCEI~A PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY SHOPE,A MINOR , ET AL TERM, -VS- CASE NO: 02-538 RONDELL J. RICE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 eCS on behalf of KEVIN GEARY~ ESQUIRE 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. eCS on behalf of DATE: 04/24/2002 KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328371 89 624 --LO 8 IN Tile MATTER OF: KJ_I',fBERLY SHOPE,A HINOE , ET AL -VS- EONDELL J. RICE COURT OF COP~40N PLEAS TERM, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUia~NT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: EDWARD E. KNAUSS IV, ESQUIRE MCS on behalf of KEVIN GEARY, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~enty (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: 04/04/2002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEARY, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624--C0 1 PAGE: 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,RASCHID & ASSOCIATES CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBEELAND VALLEY EMS CHAMBERSBURG IMAGING ASSOC. CUMBERLAND VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURIE MAYNARD VALLEY MEDICAL CENTER 30HN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624 --CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE. & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-~ TO: CUSTODIAN OF RECORDS FOR: APPALACHAIN ORTHOPAEDIC CENTER (Name of Person or Entity) things:Within twenty (20) days after service of this SUbsE~oenaAT~GiqE~ou ar ordered by the court to produce the following documents or at MCS GROUP INC., 1601 MukRKET ST., #800,PHILA. ,PA 19103 (AddressI 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: KEVIN GEARY~ ESQ. ADDRESS: 1601 MARKET ST. PHILA.~PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: APPALACHIAN ORTHOPEDIC CENTER 1 DUNWOODY DR. CARLISLE, PA 17013 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366186 89 6~ --LO8 CERTIFICATE PREiAEQUISITE TO JER';ICE OF A SL'ZPCENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY SHOPE,A MINOR , ET AL TERM, -VS- CASE NO: 02-538 RONDELL J. RICE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE certifies that (i) 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: 04/24/2002 KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328372 89 624 --LO 9 C Ob~40 ~/~ T H OF PENNS 5Vitb~IA C O~3~.'TY OF C '3} ~ ...~_, E ?~I ~ ,_~/~D IN THE MATTER OF: KIM~E~LY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COUKT OF C0~40N PLEAS TERM, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCTD~.NTS AND THINGS FOR DISCOv~-R~ PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: EDWARD E. KI~AUSS IV, ESQUIRE MCS on behalf of KEVIN GEA~Y, ESQUIP. E 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: 0410412002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 MC$ on behalf of KEVIN GEA~Y, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET f800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624--CO1 PAGE: 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,RASCHID & ASSOCIATES CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBEP. LAND VALLEY EMS CHAMBERSBURG IMAGING ASSOC. CUMBERLAND VALLEYMED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURIE MAYNARD VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBEKLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE. & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,?? TO: CUSTODIAN OF RECORDS FOR:ORTHOPAEDIC ASSOC. (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 at MCS GROUP INC., 1601 MARKET ST., #800,PHILA.,PA 19103 (Address) You may deliver or mall 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: KEVIN GEARY~ ESQ. ADDRESS: 1601 MARKET ST. PHILA.~PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: A~rORNEY FOR: DEFENDANT DATE: )J'L~_~,ffc~ ~, .Z~.Z~ BY T~E COURT.; '~ Prothonota~j/Cl~k~ Civil Division I / Deputy Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC ASSOCIATES 1035 WAYNE AVENUE CHAMBERSBURG, PA 17201 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366188 8 9 624 --LO 9 CERTIFICATE PKEiL~QUI$ITE TO SERVIgE OF A SU~PO~.Ih% PURSUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/24/2002 MCS on behalf of REVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328373 89624--L10 C O lvi140 N-~rf~A r - T H OF P E NN S 1'I~V~lq IA IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF C0fgi0N PLEAS TERM, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUNRNTS AND THINGS FOR DISCovERY PURSUANT TO RULE 4009.2] [ Note: see enclosed list of locations ] TO: EDWARD E. KNAUSS IV, ESQUIRE MCS on behalf of KEVIN GEARY, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04/04/2002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 MOS on behalf of KE~IN GEARY, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact TRE MCS GROUP INC. 1601 MAK~T STREET t800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624 --CO 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAME PAGE: 1 MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INS[IRANCE ORNDORF,RASCHID & ASSOCIATES T~AVE~LMRS INEU~F~AMC~ fifl~A'~ CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CI~IBERLAND VALLEY EMS CHAMBERSBURG IMAGING ASSOC. CUMBEILLAND VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURIE MAYNARI) VALLEY MEDICAL CENTER JOHN C. CARIgY, M.D. TRAVELERS INS~CE COMPANY DE02-183461 896:;>4 --CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMbf:RLAN i) KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS : VS : RONDELL J. RICE : File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,?? TO: CUSTODIAN OF RECORDS FOR: MS LAURIE MAYNARD (Name of Person or Entity) Within twenty (20) days after service of this subl~oena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800,PHILA. ,PA 19103 -- (Address) 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: KEVIN GEARY, ESq. ADDRESS: 1601 MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-2/.6-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court BY THE COURT: Prothonotary/~erl~Civil Olv s on / } Deputy (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MS. LAURIE MAYNARD 46 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257 RE: 89624 KIMBERLY SHOPE ANY AND ALL RECORDS Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366190 89 624--L10 CERTIFICATE PP2~REQU!SITE T9 SFIIVICE CF A SU~POENA PUI~SUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/24/2002 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328374 8 9 6 2 4 --L1 1 IN THE MATTER OF: KIMBERLY SH0PE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF CO~0N PLEAS TERM, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND T~INGS FOR DISCOVERY PURSUANT TO RULE 4009.2] [ Note: see enclosed list of locations ] TO: EDWARD E. KNAUSS IV, ESQUIRE MCS on behalf of KEVIN GEA~Y, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04~04~2002 CC: KEVIN GEAI~Y, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact TH~ MCS GROUP INC. 1601 MARXET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89 624--CO 1 PAGE: 1 RECORDS REQUESTED >>> LOCATION LIST <<< LOCATION NAHE MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSURANCE ORNDORF,RASCHID & ASSOCIATES CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBERLAND VALLEY EMS CHAMBERSBURG IMAGING ASSOC. CUMBERLAND VALLEY HED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURIE MAYNARD VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624--C01 COMMONWEALTH OF PENNSYLVANL4 COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE. & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS : VS : : RONDELL J. RICE : File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,?? TO: CUSTODIAN OF RECORDS FOR: VALLEY MEDICAL GROUP (Narae of Person or Entity) Within twenty (20) days after service of this subooena, you are ordered by the court to produce the following documents or things: SEE ATT'ACHED at MCS GROUP INC., 1601 MARKET ST., #800,PHILA.,PA 19103 -- (Address) 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: KEV'tN GEARY, ESq. ADDRESS:160I MARKET ST. PHILA.,PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court BY THE COUR. T: r~ Prothonotary/(~lerk~ C vii D vision / / Depu~ (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: VALLEY MEDICAL CENTER 411 SOUTH FAYETI'E STREET SHIPPENSBURG, PA 17257 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. ~ua.t? Requested: up to and including the present. bject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security ~.- 186-66-2177 Date of Birth: 08-21-1984 SU10-366192 89 624--Lll CERTIFICATE PPd~REQUI$IT~ TO SEXViCZ OF A SULPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE 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, includin§ the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/24/2002 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328375 8 9 624--L12 C O lv/lvIo l~II~ "'-A r - T H OF P E NN S 1'I. V~a~I~ IA C OT3~ITY CF IN THE MATTER OF: KIMBE~LY SHOPE,A MINOR , ET AL -VS- RONDELL J. RICE COURT OF CO~{ON PLEAS TERM, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMRNTS AND ·rniNGS FOR DISCOVERY PURSUANT TO RULE 4009.2] [ Note: see enclosed list of locations ] TO: EDWARD E. KNAUSS IV, ESQUIRE MCS on behalf of KEVIN GEARY, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the andersi§ned 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 completin§ the attached counsel card and returnin§ same to MCS or by contactinE our local MCS office. DATE: 04/04/2002 CC: KEVIN GEARY, ESQUIRE - 0548-80254 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET $800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624--60 1 PAGE: 1 RECORDS REQUESTED MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS OTHER MEDICAL RECORDS MEDICAL RECORDS INSUP, ANCE >>> LOCATION LIST <<< LOCATION NAME ORNDORF,RASCHID & ASSOCIATES CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CUMBERLAND VALLEY EMS CHAMBERSBURG I]4AGING ASSOC. CUMBERLAND VALLEY MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOCIATES MS. LAURIE MAYNARD VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COMPANY DE02-183461 89624--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMB[rRLAN D KIMBERLY SHOPE, A MINOR, BY LASHELL SHQPE & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS VS RONDELL J. RICE : File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009 ?? TO: CUSTODIAN OF RECORDS FOR: JOHN C. CAREY, M.D. (Name of Per, on 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 at MCS GROUP INC. , 1601 MARKET ST. , #800,PHILA. ,PA 19103 (Address) 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: KEVIN GEARY, ESQ. ADDRESS: 1601 MARKET ST. PHILA.. PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATrORNEY FOR: DEFENDANT DATE: Seal of the Court BY THE COUI~T:/9 Prothonotary/Cl~rl~ Civil Division ! ! Deputy (Elf. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN C. CAREY, M.D. UNIV. PHYSICIANS GROUP 670 CHERRY DRIVE HERSHEY, PA 17033 RE: 89624 KIMBERLY SHOPE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366194 89624--L12 CERTIFICATE PPJ~KEQUISITE TO .eEP, VICE OF ~. $~PQM~L~ PUI~SUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY SHOPE,A MINOR , ET AL COURT OF COMMON PLEAS TERM, RONDELL J. RICE -VS- CASE NO: 02-538 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of KEVIN GEARY, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/2~/2002 MCS on behalf of KEVIN GEARY, ESQUIRE Attorney for DEFENDANT DEll-328376 8 9 624--L1 3 C O lvllvlO I~V~-~'~- ~L, T H OF P E NN S '~']_.V~l~ IA IN THE HATTER OF: KIMBERLY SHOPE,A HINOR , ET AL -VS- C0~RT OF !C0~ION PLEAS CASE NO: 02-538 RONDELL J. RICE NOTICE OF II~TgN~ TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN~ TO RULE 4009.21 [ Note: see enclosed list of locations ] TO= EDWARD E. KNAUSS IV, ESQUIRE HCS on behalf of KE~IN GEARY, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fro~ the date listed below in which to file of record end 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 completin8 the attached counsel card and returning same to MCS or by contacting our local MC8 office. DA'rE: 0~10~12002 CC: ~vIN GRARY, ESQUIRE - 0548-80254 MCS on behalf of KEv-IN GEARY, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact x~ HCS GROUP INC. 1601HARKET STREET $800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-183461 89624--CO1 3. RECORDS ~EqOESz~ LOCATION LIST <<< LOCATION HEDICAL RECORDS INSUP~C= HEDICAL RECORDS INSURANCE HEDICAL RECORDS HEDICAL RECORDS MEDICAL ~ECORDS HEDICAL RECORDS HEDICAL RECORDS OTm~.R HEDICAL RECORDS MEDICAL RECORDS IIqSURANC~ ORNDORF,RASCHID & ASSOCIATES TEA%'~LZ~S INSUREANC~- COHPAL'Y CHAMBERSBURG HOSPITAL ALLSTATE INS. CO. CHAMBERSBURG IHAGING ASSOC. CUMBE]{LAND VA].L~y MED. SRVC. APPALACHIAN ORTHOPEDIC CENTER ORTHOPEDIC ASSOC].ATES VALLEY MEDICAL CENTER JOHN C. CAREY, M.D. TRAVELERS INSUREANCE COHPANY DE02-183461 89624--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPK & RICHARD SHOPE, HER PARENTS & NATURAL GUARDIANS ' VS : RONDELL J. RICE : File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: TRAVELERS INSURANCE CO. (Name of Pet~on or £ntityI Within twenty (20) days after service of this su~e~t~]~rdered by the coul~ to produce the following documents or things: at MCS GROUP INC., 1601 MARKET ST., #800,PHILA.,PA 19103 (Address) 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 li~ed above. You have the right to seek, in advance, the reasonable cost of preparing the copie~ 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 par~y serving this subpoena may seek a cour~ order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: KEVIN GEARY, ESQ. ADDRESS: 1601 MARKET ST. PHILA. , PA 19103 TELEPHONE: 215-246-0900 SUPREME COURT ID #: A~'~ORNEY FOR: DEFENDANT DATE: BY THE COURT: Pro'h-on otary/C~r O~ivil Division J / Depu~ Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TRAVELERS INSUREANCE COMPANY P.O.. BOX 14385 READING, PA 196123485 RE-- 89624 KIMBERLY SHOPE CLAIM g278SAJ8815,THIS IS ALSO FOR THE 12-4-97 (MAYBE 12-3-97)ACCIDENT Any and all claims files. Dates Requested: up to and including the pr~-~ent. Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-366196 89624--L13 SWARTZ, CAMPBELL & DETWEILER BY: KEVIN M. GEARY, ESQUIRE Attorney ID No. 67361 1601 Market Street - 34th Floor Philadelphia, Pennsylvania 19103 (215)299-4362 File No.: 0548-80254 Attorney for Defendant, Rondell J. Rice KIMBERLY SHOPE, Minor, by LASHELL SHOPE and RICHARD SHOPE, her parents and natural guardians VS. RONDELLJ. RICE COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 02-538 WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance as counsel of record on behalf of Defendant, Rondell J. Rice. WE1LER I~EVI~N M. GI~ARY, ESQUI~ I.D. No. 67361 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance as counsel of record on behalf of Defend~fl.,-Rund~ J. Rice. BELl ILER k.~EA9 F. KENNEDY, ',SQUIRE I.D. NO. 54264 ~WARTZ, CAM[~B£LL ~:~ DETWEILER ATTORNEYS AT LAW '1601 MARKET STREET '341H FLOOR o PHILADELPHIA, PA CERTIFICATE PKEP. EQUISITE TO SEI~VICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY SHOPE, A MINOR, ET AL TERM, -VS- CASE NO: 02-538 RONDELL J. RICE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SEAN F. KENNEDY, ESq. certifies that (1) A notice-of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 05/23/2002 _~b~h~ 1 f of Attorney for DEFENDANT DEll-334926 896:;4--L14 COI~lVlOSII~ALTH OF PENNSYLVANIA COUNTY OF CI31~BERLAND IN THE MATTER OF: KIMBERLY SHOPE, A MINOR, ET AL -VS- RONDELL J. RICE COURT OF C0~40N PLEAS TERM, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVER][ PURSUANT TO RUr.H 4009.21 MCDONA!.]~ · S HATTm~W CROSBY, ESQ. OTI~R TO: EDI~ARD g. KNAUSS IV, ESQ. MCS on behalf of SKAN F. A~q~DZ, 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 subpoe-- 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 H CS or by contacting our local MCS office. DATE: 05/03/2002 CC: SEAN F. KENNEDY, ESQ. - 0548-80254 HCS on behalf of SEANF. ~3~r~y, ESq. Attorney for DEFENDANT Any questions regarding this matter, contact TN MCS GROUP INC. 1601HARK ET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-18§121 89624--C01 COMMON'WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE AND RICHARD SHOPE, HER PARENTS AND NATURAL : GUARDIANS : : VS : RONDELL J. RICE : : File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGE FOR DISCOVERY PURSUANT TO RULE 4009_~ TO: CUSTODIAN OF RECORDS FOR: MCDONALD'S (Name of Person or EAtity) Within twenty (20) days after service of this subpoena, you are ordered by the court to p~Gduce the followifl8 documents or thinss: SEE ATTACR_~_ at MCS GROUP INC. ~' 1601 MARKET STREET, SUITE 800; PtIIT.AnELPHIA PA 19103 (Address) YOU may deliver or mail lesible copies of the documents or produce thiflp requested by this subpoena, tofsther with the certificate of compliance, to the par~ m,lkin8 this request at the address listed above. You have the risht to seek, in advance, the reasonable cost of preparin$ the copies or producin$ the thinSs sought. If you fail to produce the documents or thinp required by this subpoena, within twenty (20) days after its service, the party servinS this subpoena may seek a court ocde~ compellinS you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SEAN F. KENNEDY, ESQUIRE ADDRESS: 1601 MARKET STREET, 34TH FLOOR PHILADELPHIA PA TELEPHONE: (215) 246-0900 SUPREME COURTID ~ ATTORNL:~'FO~ THE DEFENDANT 19103 Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MCDONALD'S 333 E. KING STREET SHIPPENSBURG, PA 17257 RE: 89624 KIMBERLY SHOPE A~NY AND ALL RECORDS Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security #: 186-66-2177 Date of Birth: 08-21-1984 SU10-371918 89624--L14 CERTIFICATE PI~gqUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY SHOPE, A MINOR, ET AL TERM, -VSo CASE NO: 02-538 RONDELL J. RICE As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SEAN F. KENNEDY, 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: 05/23/2002 SEAN F. KENNEDY~ Esq. Attorney for DEFENDANT DEll-334927 89624--L15 CO~fl~IOSVwq~ALTH OF PENNSYLVANIA COUNTY OF CU~4RERLAND IN THE MATTER OF: KIMBERLY SHOPE, A MINOR, ET AL -VS- RONDELL J. RICE COURT OF CO~ON PLEAS TE~, CASE NO: 02-538 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE ~S ~Mn T~.L!~KT~ ~'O~t DZ~CowsK~ ~,tj~..~AI~T TO R_lifl'.Jt 4009.21 MATT~CROSBY, ESQ. TO= EDlfAen E. KHAUSS IV, ESQ. MCS on behalf of SKAH P. KKI~KDY, ESq. intends to serve a subpoena identical to the one that is attached to this notice. You have twant! (20) days from the date ltsted belowinwh~ch to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day noticepertod is waived or if no objection i8 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 returni-$ se~e to MCS or by contacting our local MCS office. DATK: 05~03~2002 cc-- SEAH F. A~mEDy, KSQ. - 0548-80254 MCS on behalf of SEAH F. rdumau~, ESq. Attorney for Da~am~NT Any questions resardin$ this matter, contact THEM CS GROUP INC. 1601 ~(aerRT STRKKT 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DK02-186121 8 9 6 2 4- -- C 0 1 COMMONWEALTH OF PENNSYLVANI.~ COUNTY OF CUMBERLAND KIMBERLY SHOPE, A MINOR, BY LASHELL SHOPE AND RICHARD SHOPE, HER PARENTS AND NATURAL : GUARDIANS : : VS : RONDELL 3. RICE : : File No. 02-538 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009 ~'~ TO: CUSTODIAN OF RECORDS FOR: MATTHEW CROSBY, ESQUIRE (N~me of P~"~on or F. nttt~) Within twenty (20) days after service of this subpoena, you ate ordered by the court to produce the following doruments things: $ ~1/2_. ATT~%~g~D Of at MCS GROUP INC. ~ 1601 MARKET STP. EET~ SUITE 800~ PHILADELPHIA PA 19103 (Addre~) You may deliver or mail legible copies of the document~ or produce things requested by this subpoena, to~ather with the certificate of compliance, to the patty making this requ~t at the add~.~ listed above. You have the right to ~ek, in advance, the reasonable co~t of p~paring the copies of ptodu~in~ the things sought. if you fail to produce the doruments or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order eomp~ilin[ you to comply with it. THIS SUBPOENA WAS ISSUE~ AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SEAlq F. KENNEDY, ESQUIRE ADDRESS: 1601 MARKET STREET, 3&TH FLOOR ~EL~',ZA ?A 19103 TELEPHONE: (215) 246-0900 SUPREME COURT 1D #: A'I'rORNEY FOR: THE DEFEffDANT DATE: Seal of the Court BYTH~COURT~ ,~ (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MATYHEW CROSBY, ESQ. 1300 LINGLESTOWN RDNO. 2 HARRISBURG, PA RE: 89624 KIMBERLY SHOPE COPY OF PREVIOUS FILE REGARDING LEGAL REPRESENTATION, ABSENT ATtORNEY/CLIENT PRIVILEDGE Subject: KIMBERLY SHOPE 56 THOMPSON CREEK DRIVE, SHIPPENSBURG, PA 17257 Social Security/~. 186-66-2177 Date of Birth: 08-21-1984 SU10-371920 89 624 --L1 5