HomeMy WebLinkAbout08-09-12 (2)David A. Mills, Esquire PA 37192
BLAKEY, YOST, BUPP & BAUSCH, LLP
17 East Market Street
York, PA 17401
(717)845-3674
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
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IN THE COURT O S OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
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.
YOST, BUPP & BAUSCH, LLP
Date: .c ~ o~ ~ ~
Attorney for Petitioner, Darlene J. Skoloda
~~1
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
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 may be
served.
Dated: a ~~
Respectfully,
BLAKEY, YOST, BUPP & BAUSCH, LLP
avi .Mills{, Esquire 17192
17 East Mazket Street
York, PA 17401
(717) 845-3674
Attorneys for Petitioner, Darlene Skoloda
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN lam: )~ ~'
Mi~C Ef~R ~Il~ a/k/a N]atbt E. ~~ a/k/a
E[F~L12 ~-E~ a/k/a Eti M. JOB,
late C~ ~ Allat Tt~nt'>shi}~,
I~oeased
File No.21-11-0851
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: RAY & Critical Care ;~-~i*p p~ociai~s, FC, 1631 N. Ftrnt stsee~t, r~r;ah,rr~,
(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 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 [D # 37192
ATTORNEY FOR: Petitioner, Darlene Skoloda
BY THE COURT:
Court
Date:
Seat of the Court
Register of Wills/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
Attorneys for Petitioner Darlene J. Skoloda
IN RE:
ESTATE OF
MARY ELEANOR JOHNS a1k/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: Pulmonary & Critical Care Medicine Associates, PC, 1631 N. Front Street, Harrisburg,
PA 17102
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 SecurityNo.: 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
7. Flow sheets;
8. Medication records;
9. Mental health treatment records;
10. 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.