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Home My WebLink About08-09-12~FCt~R~G'~FFiGE E3 ~~~a:'~ i ~~~~h~ 4~~~e a David A. Mills, Esquire PA 37192 ~~;~ AU^ BLAKEY, YOST, BUPP & BAUSCH, LLP " ~9 P~ ~' ~F 17 East Market Street - ; „ .;,; York, PA 17401 "`' `~ "" '' (717) 845-3674 O1SPHr~N~s COU`~i 1 Attornevs for Petitioner Darlene J. Skoloda C(~IrtBFR1ANl) ~' ~ IN RE: : IN THE COURT OF COMMONPLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF MARY ELEANOR JOHNS a/k/a MARY E. JOHNS a/k/a MARY JOHNS a/k/a ELEANOR JOHNS a/k/a ELEANOR M. JOHNS, Late of Upper Allen Township, Deceased ORPHANS' COURT DNISION No. 21-11-0851 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, David A. Mills, 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 (20) 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. BLAKEY, YOST, BUPP ¢~ BAUSCH, LLP Date: d s ~ o. ~ . Mi s, Esquire Attorney for Petitioner, Darlene J. Skoloda David A. Mills, Esquire PA 37192 BLAKEY, YOST, BUPP & BAUSCH, LLP 17 East Market Street York, PA 17401 (717) 845-3674 Attorney for Petitioner, Darlene J. Skoloda IN RE: ESTATE OF MARY ELEANOR JOHNS a/k/a MARY E. JOHNS a/k/a ELEANOR JOHNS a/k/a ELEANOR M. JOHNS, Late of Upper Allen Township, Deceased IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION No. 21-11-0851 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff intends to serve subpoenas identical to the ones that are 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 subpoenas. If no objections are made, the subpoena maybe served. Dated: dt, a ~~ Respectfully, BLAKEY, YOST, BUPP &,BAUSCH, LLP avi . Mill, Esquire ~A 37192 17 East Market Street York, PA 17401 (717) 845-3674 Attorneys for Petitioner, Darlene Skoloda COPAMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN 1~: ~ CF N1al2Y,RY Ef~PKR ~-Il~ a/k/a [~ E. xI~ a/k/a 21-11-0851 EfFi~i'~ ,kEV~ a/k/a FT}~I~R Ni. ~, File No. Ir76e c8 LIR~eC' Alle't yip, Ll~oeased SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Neplav'la-~ Pseoraa~h~s crE ~.al PA. Irtc., 205 C~a:dview Ave~te, Stut~e 402, (Name of Person or Entity) Hi 11, pp~ ,17011 Within twenty (20) days after service of this subpoena, you arse oDrdered by the court to produce the following documents or things: See Attachment to the Subpoena. at 17 East Market Street, York, PA 17401 (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 addross 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: David Mills, Esquire ADDRESS: 17 East Market Street York. PA 17401 TELEPHONE: 717-845-3674 SUPREME COURT ID # 37192 ATTORNEY FOR: Petitioner, Darlene Skoloda Court Date: Seal of the Court BY THE COURT: Register ofWills/Clerk of the Orphans' Deputy David A. Mills, Esquire PA 37192 BLAKEY, YOST, BUPP & BAUSCH, LLP 17 East Market Street York, PA 17401 (717) 845-3674 Attornevs for Petitioner. Darlene J. Skoloda IN RE: ESTATE OF MARY ELEANOR JOHNS a/k/a MARY E. JOHNS a/k/a MARY JOHNS a/k/a ELEANOR JOHNS a/k/a ELEANOR M. JOHNS, Late of Upper Allen Township, Deceased IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DNISION No. 21-11-0851 ATTACHMENT TO SUBPOENA TO: Nephrology Associates of Central PA, Inc., 205 Grandview Avenue, Suite 402, Camp Hill, PA 17011 All documents pertaining to the following individual from December 1, 2009 until death on July 23 2011, as well as post - mortem through May 31, 2012, including but not limited to: Name: Mary Eleanor Johns, a/k/a Mary E. Johns a/k/a Mary Johns a/k/a Eleanor Johns a!k/a Eleanor M. Johns Address: 814 Flintlock Ridge Road, Mechanicsburg, PA 17055 Date of Birth: December 12, 1920 Date of Death: July 23, 2011 Social Security No.: 174-16-2634 1. Office visits; 2. Admissions; 3. Intake patient survey/Medical history; 4. Physician's notes; 5. Nurses' notes; 6. Social Worker notes i . Flow sheets; 8. Medication records; 9. Mental health treatment records; lU. Consent forms; 11. Preoperative records; 12. Correspondence (including letters, a-mail and computer correspondence, including correspondence to and from attorneys); 13. Telephone notes/reports; 14. Laboratory & pathology reports; 15. Hospital records; 16. Consultation records/reports/correspondence; 17. Test results; 18. Radiology reports; ' 19. Radiology films (if large number please call before sending); 20. Itemized statements for services rendered; 21. All records inpatient's file including records from other health care providers; 22. All bills and invoices; 23. Insurance forms; 24. Advance directives; 25. Medical Power of Attorney; 26. HIPAA documents. If you have any documents relating to this patient that you are not producing, please provide a list of any such documents.