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Home My WebLink About12-5043..? 1 iti i It i rClO {FCS?I ANGINO & ROVNER, P.C. Neil J. Rovner Attorney ID# : 22108 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: nrovner@angino-rovner.com ERI_tD C 0 U N Y THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; JAMES F. RICH, M.D., P.C.; KENNETH B. CONNOR, M.D.; PINNACLE HEALTH MEDICAL GROUP, INC. d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP), Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. ? a CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILLING 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 JUDGEMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 504815 4s> ? ? ggas NOTICIA USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las sigurentes PAGINAS, USTED TIENEN QUE TOMAR ACCION DENTRO VEINTE (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un aborgado y archivando por escrito con la Corte sus defenses o objections a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerio el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted pro la Corte sin mas aviso por cualquier dinero reclamando en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o ostros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGANDO ENSEGUIDA. SI USTED NO TIENE UN ABORGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 2 ANGINO & ROVNER, P.C. Neil J. Rovner Attorney ID# : 22108 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 .Attorneys for Plaintiff(s) E-mail: nrovner@angino-rovner.com THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; JAMES F. RICH, M.D., P.C.; KENNETH B. CONNER, M.D.; PINNACLE HEALTH MEDICAL GROUP, INC. d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP), Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Ronald J. Walsh, the brother of Mary Frances Walsh, the Plaintiff's decedent, is an adult individual and citizen of the Commonwealth of Pennsylvania who resides in Philadelphia, Philadelphia County, Pennsylvania. 2. Plaintiff Ronald J. Walsh (hereinafter "Plaintiff Walsh") has been named the Executor of the Estate of Mary Frances Walsh, deceased, by Letters Testamentary granted by the Register of Wills of Cumberland County, Pennsylvania. 3. Defendant James F. Rich, M.D. (hereinafter "Defendant Rich") is a licensed physician holding himself out as a specialist in internal medicine who at all relevant times was 504815 the employee, agent or apparent agent of Rich Connor Associates (A Division of Heritage Medical Group, LLP), with offices at 207 House Avenue, Suite #101, Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiff is asserting a professional liability claim against the Defendant. A Certificate of Merit is filed herewith. 4. Defendant James F. Rich, M.D., P.C. is a licensed healthcare facility providing comprehensive medical services located in Camp Hill, Cumberland County, Pennsylvania. Plaintiff is asserting a professional liability claim against the Defendant. A Certificate of Merit is filed herewith. 5. Defendant Kenneth B. Connor, M.D. (hereinafter "Defendant Connor") is a licensed physician holding himself out as a specialist in internal medicine who at all relevant times was the employee, agent or apparent agent of Pinnacle Health Medical Group, Inc. d/b/a Conner, Kusztos Associates, formerly Rich Connor Associates (A Division of Heritage Medical Group, LLP) with offices at 207 House Avenue, Suite #101, Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiff is asserting a professional liability claim against the Defendant. A Certificate of Merit is filed herewith. 6. Defendant Pinnacle Health Medical Group, Inc. d/b/a Conner, Kusztos Associates, formerly Rich Conner Associates (A Division of Heritage Medical Group, LLP), (hereinafter "Defendant Rich Conner Associates") is a licensed healthcare facility providing comprehensive medical services located in Camp Hill, Cumberland County, Pennsylvania. Plaintiff is asserting a professional liability claim against the Defendant. A Certificate of Merit is filed herewith. 7. Defendant Rich Conner Associates at all relevant times was the employer of Defendant Rich and Defendant Connor, and all other medical personnel treating Mary Frances Walsh between September 21, 2004, and August 18, 2010. 4 8. Plaintiff s Decedent, Mary Frances Walsh, died August 18, 2010, as a result of heart problems undetected by Defendant Rich, Defendant Connor and Defendant Rich Conner Associates. 9. The facts and occurrences hereinafter related took place on or about September 21, 2004. 10. Mary Frances Walsh had been a patient of Defendant Rich Conner Associates and Defendant Rich and Defendant Connor for many years prior to September 22, 2004. 11. On or about that date, Mary Frances Walsh was admitted to Burdette Tomlin Memorial Hospital in Cape May Court House, New Jersey while on vacation. 12. At that time and place, Mary Frances Walsh was admitted to Burdette Tomlin Memorial Hospital with complaints of profound weakness, shortness of breath and fatigue for three weeks. 13. Mary Frances Walsh had been seen in the offices of Dr. Michael Moroldo in New Jersey prior to admission with the finding of Diffusely Ischemic EKG and Bilateral Carotid Bruits. 14. On or about September 21, 2004, Dr. Moroldo notified Defendant Rich Conner Associates of EKG changes and the planned admission to Burdette Tomlin Memorial Hospital. 15. On or about September 23, 2004, Mary Frances Walsh underwent an echocardiogram showing Mitral Valve Prolapse and Aortic Stenosis. 16. On or about October 7, 2004, Mary Frances Walsh was seen at Defendant Rich Conner Associates where she was again noted to have been hospitalized at Burdette Tomlin Memorial Hospital. 5 17. At no time did Defendants Rich, Connor or Rich Conner Associates follow-up on Mary Frances Walsh's heart related problems diagnosed at Burdette Tomlin Memorial Hospital from September 23, 2004, until June 2010. 18. Mary Frances Walsh was unaware that she was diagnosed with Mitral Valve Prolapse and Aortic Stenosis. 19. Defendants informed Mary Frances Walsh that her symptoms were due to thyroid problems with possible Grave's Disease. 20. As a result, Defendant Rich Conner Associates referred her to an endocrinologist, Dr. Joshie. 21. Between October 7, 2004 and June 2010, Mary Frances Walsh was seen by Defendant Rich Conner Associates at least twenty (20) times. 22. At no time was she informed that she needed to be seen by a cardiologist or cardiothoracic surgeon because of her heart valve problems. 23. At no time between October 7, 2004 and June 2010, was Mary Frances Walsh referred to a cardiologist or cardiovascular surgeon for evaluation. 24. On or about May 30, 2010, Mary Frances Walsh was admitted to Holy Spirit Hospital with complaints of shortness of breath, atrial fibrillation, severe mitral valve regurgitation and severe pulmonary hypertension. 25. For the first time, Mary Frances Walsh was referred to the Moffitt Heart Group for evaluation of her heart problems. 26. The Moffitt Heart Group determined that because of Mary Frances Walsh's then existing medical condition she was not a candidate for valve repair or replacement. 27. On or about August 3, 2010, Mary Frances Walsh was admitted to Holy Spirit Hospital for a progressive shortness of breath. 6 28. On or about August 6, 2010, Mary Frances Walsh underwent an attempted cardioversion for her atrial fibrillation. 29. Despite the cardioversion, Mary Frances Walsh returned to her irregular heart rhythm. 30. On or about August 9, 2010, Mary Frances Walsh underwent an attempt to place a pacemaker for her rhythm disturbance. 31. At that time a cardiac perforation and tamponade occurred. 32. From that date until her death, Mary Frances Walsh was placed on a ventilator and developed an infection and pneumonia. 33. As a result of the failure of the Defendants noted above, Plaintiff died on August 18, 2010. COUNTI THE ESTATE OF MARY FRANCES WALSH BY HER EXECUTOR, RONALD J. WALSH V. JAMES F. RICH, M.D. 34. Paragraphs 1 through 33 are incorporated herein by reference. 35. Defendant James F. Rich, M.D., was negligent, careless and violated the appropriate standards of care for: a. failure to consult with cardiologist or cardiovascular surgeons following September 2004 to allow for repair or replacement of Mary Frances Walsh's heart valve before her condition made this impossible; b. failure to notify Mary Frances Walsh of her condition and the possibility it could be treated with surgery; C. failure to obtain the records from Burdette Tomlin Memorial Hospital to determine the condition of Mary Frances Walsh's heart; d. failure in delaying the treatment of Mary Frances Walsh's heart condition until she was unable to have definitive surgery; and 7 e. failure to properly follow-up on Mary Frances Walsh's heart condition, therefore, increasing the risk of Mary Frances Walsh's death. WHEREFORE, Plaintiff The Estate of Mary Frances Walsh by her Executor, Ronald J. Walsh, demands judgment against Defendant James F. Rich, M.D., in an amount excess of fifty thousand ($50,000) dollars, exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. COUNT II THE ESTATE OF MARY FRANCES WALSH BY HER EXECUTOR, RONALD J WALSH V. JAMES F. RICH, M.D., P.C. 36. Paragraphs 1 through 35 are incorporated herein by reference. 37. Defendant James F. Rich, M.D., P.C., through its employee, agent and servant, Defendant James F. Rich, M.D. is negligent and increased the risk of harm to Mary Frances Walsh which harm was suffered as a result of his negligence set forth in Paragraph 35 above. WHEREFORE, Plaintiff The Estate of Mary Frances Walsh by her Executor, Ronald J. Walsh, demands judgment against Defendant James F. Rich, M.D., P.C., in an amount excess of fifty thousand ($50,000) dollars, exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. COUNT III THE ESTATE OF MARY FRANCES WALSH BY HER EXECUTOR, RONALD J WALSH V. KENNETH B. CONNOR,_ M.D. 38. Paragraphs 1 through 37 are incorporated herein by reference. 39. Defendant Kenneth B. Connor, M.D., was negligent, careless and violated the appropriate standards of care for: a. failure to consult with cardiologist or cardiovascular surgeons following September 2004 to allow for repair or replacement of 8 Mary I, rances Walsh's heart valve before her condition made this impossible; b. failure to notify Mary Frances Walsh of her condition and the possibility it could be treated with surgery; C. failure to obtain the records from Burdette Tomlin Memorial Hospital to determine the condition of Mary Frances Walsh's heart; d. failure in delaying the treatment of Mary Frances Walsh's heart condition until she was unable to have definitive surgery; and e. failure to properly follow-up on Mary Frances Walsh's heart condition, therefore, increasing the risk of Mary Frances Walsh's death. WHEREFORE, Plaintiff The Estate of Mary Frances Walsh by her Executor, Ronald J. Walsh, demands judgment against Defendant Kenneth B. Connor, M.D., in an amount excess of fifty thousand ($50,000) dollars, exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. COUNT IV THE ESTATE OF MARY FRANCES WALSH BY HER EXECUTOR, RONALD J WALSH V PINNACLE HEALTH MEDICAL GROUP, INC d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP) 40. Paragraphs 1 through 39 are incorporated herein by reference. 41. Defendant Pinnacle Health Medical Group, Inc d/b/a Conner, Kusztos Associates, formerly Rich Conner Associates (A Division of Heritage Medical Group, LLP), through its employees, agents and servants, including Defendants James F. Rich, M.D. and Kenneth Connor, M.D. are negligent and increased the risk of harm to Mary Frances Walsh which harm was suffered as a result of their negligence set forth in Paragraph 35 and Paragraph 39 above. WHEREFORE, Plaintiff The Estate of Mary Frances Walsh by her Executor, Ronald J. Walsh, demands judgment against Defendant Pinnacle Health Medical Group, Inc d/b/a Conner, 9 Kusztos Associates, formerly Rich Conner Associates (A Division of Heritage Medical Group, LLP), in an amount excess of fifty thousand ($50,000) dollars, exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. CLAIM I - SURVIVAL ACTION THE ESTATE OF MARY FRANCES WALSH BY HER EXECUTOR, RONALD J WALSH V JAMES F RICH, M.D.; JAMES F. RICH, M.D., P.C.; KENNETH B CONNOR, M.D. AND PINNACLE HEALTH MEDICAL GROUP, INC d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP) 42. Paragraphs 1 through 41 are incorporated herein as if set forth at length. 43. As a further result of the injuries suffered by Decedent Mary Frances Walsh, she has incurred loss of earning capacity and claim is made therefor. 44. As a result of the injuries suffered by Decedent Mary Frances Walsh, has sustained loss of life's pleasures and claim is made therefor. 45. As a result of the injuries suffered by Decedent Mary Frances Walsh, she has been forced to incur pain and suffering and claim is made therefor. 46. As a result of the injuries suffered by Decedent Mary Frances Walsh, she has been forced to incur medical expenses, and claim is made therefor. 47. Decedent Mary Frances Walsh, was seventy-five (75) years of age having been born on September 17, 1934. WHEREFORE, Plaintiff The Estate of Mary Frances Walsh by her Executor, Ronald J. Walsh, demands judgment against Defendants James F. Rich, M.D.; James F. Rich, M.D., P.C.; Kenneth B. Connor, M.D. and Pinnacle Health Medical Group, Inc d/b/a Conner, Kusztos Associates, formerly Rich Conner Associates (A Division of Heritage Medical Group, LLP), in 10 an amount excess of fifty thousand ($50,000) dollars, exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. CLAIM II - WRONGFUL DEATH THE ESTATE OF MARY FRANCES WALSH BY HER EXECUTOR, RONALD J WALSH V JAMES F RICH, M.D.; JAMES F. RICH, M.D., P.C.; KENNETH B CONNER, M.D. AND PINNACLE HEALTH MEDICAL GROUP, INC d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP) 48. Paragraphs 1 through 47 are incorporated herein as if set forth at length. 49. Plaintiff Ronald J. Walsh, is the brother of Decedent and claims damages for the harm and injuries of Mary Frances Walsh averred above pursuant to Pennsylvania's Wrongful Death Act, 42 P.S. § 8301. 50. Decedent Mary Frances Walsh's harm and injuries resulted from the acts and omissions of Defendants as set forth above. 51. The following is the name of persons entitled by law to recover for damages for such wrongful death and their relationship to decedent: Name Relationship Address Ronald J. Walsh Brother Philadelphia, PA James Walsh Brother Hillsborough, NJ 52. As a direct and proximate result of the Defendants' negligence as alleged herein, and incorporated herein by reference as if set forth at length, Mary Frances Walsh died. Her death could have been prevented and would not have occurred but for the Defendants' negligence. 53. As a direct and proximate result of the Defendants' negligence, Plaintiff Ronald J. Walsh incurred funeral, burial and related expenses, as well as expenses for the Executor of the Decedent's Estate, all of which a claim is made therefor. WHEREFORE, Plaintiff The Estate of Mary Frances Walsh by her Executor, Ronald J. Walsh, demands judgment against Defendants James F. Rich, M.D.; James F. Rich, M.D., P.C.; Kenneth B. Connor, M.D. and Pinnacle Health Medical Group, Inc d/b/a Conner, Kusztos Associates, formerly Rich Conner Associates (A Division of Heritage Medical Group, LLP), in an amount excess of fifty thousand ($50,000) dollars, exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. ANG1NO & ROVNER, P.C. Neil J. Rovner s ire I.D. No. 22.1 4503 N. Front Street Harrisbuig, PA 17110 (717) 238-6791 Counsel for Plaintiff(s) Date: Auguste' , 2012 12 VERIFICATION 1, Ronald J. Walsh, Plaintiff, have read the foregoing Complaint and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of. 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. Witness 1 Dated: Ronald J. Walsh Z Date: ?I/e!(lz( I 504554 ANGINO & ROVNER, P.C. Neil J. Rovner Attorney ID# : 22108 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: nrovner@angino-rovner.com THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; JAMES F. RICH, M.D., P.C.; KENNETH B. CONNOR, M.D.; PINNACLE HEALTH MEDICAL GROUP, INC. d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP), Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED Certificate of Merit as to James F. Rich, M.D. I, Neil J. Rovner, certify that: ( ) an appropriate licensed professional has supplied a written statement to the und, rsigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; AND/OR ( ) the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR ( ) expert testimony of an appropriate licensed professional is unrgcessary for prosecution of the claim against this defendant. Date: August/CL , 2012 Neil J. Rovner 14 ANGINO & ROVNER, P.C. Neil J. Rovner Attorney 1134 : 22108 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: nrovner@angino-rovner.com THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; JAMES F. RICH, M.D., P.C.; KENNETH B. CONNOR, M.D.; PINNACLE HEALTH MEDICAL GROUP, INC. d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP), Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED Certificate of Merit as to James F. Rich, M.D., P.C. I, Neil J. Rovner, certify that: ( jy ) an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; AND/OR ( ) the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR ( ) expert testimony of an appropriate licensed profession 1 unnecessary for prosecution of the claim against this defendant. Date: August / ` , 2012 p, Neil J. Rovner 15 ANGINO & ROVNER, P.C. Neil J. Rovner Attorney ID# : 22108 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: nrovner@angino-rovner.com THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; JAMES F. RICH, M.D., P.C.; KENNETH B. CONNOR, M.D.; PINNACLE HEALTH MEDICAL GROUP, INC. d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP), Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED Certificate of Merit as to Kenneth B. Connor, M.D. I, Neil J. Rovner, certify that: an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; AND/OR ( ) the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR ( ) expert testimony of an appropriate licensed professional is/ unnecessary for prosecution of the claim against this defendant. Date: August D , 2012 Neil J. Rovner 16 ANGINO & ROVNER, P.C. Neil J. Rovner Attorney ID# : 22108 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: nrovner@angino-rovner.com THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; JAMES F. RICH, M.D., P.C.; KENNETH B. CONNOR, M.D.; PINNACLE HEALTH MEDICAL GROUP, INC. d/b/a CONNER, KUSZTOS ASSOCIATES, formerly RICH CONNER ASSOCIATES (A DIVISION OF HERITAGE MEDICAL GROUP, LLP), Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED Certificate of Merit as to Pinnacle Health Medical Group, Inc. d/b/a Conner, Kusztos Associates, formerly Rich Conner Associates (A Division of Heritage Medical Group, LLP) I, Neil J. Rovner, certify that: ( ) an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; AND/OR ( ) the claim that this defendant deviated from an acceptable professional standard is ba§ed solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR ( ) expert testimony of an appropriate licensed professional./is unhec?essdry for prosecution of the claim against this defendant. Date: August , r 2012 Neil J. Rovner- 17 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff . ! J - O 1= F I CL z4,tst`, r w t?„ ? rj H0N0TAR Jody s smith Chief Deputy 2012 SEP -6 AM In: 14 Richard W Stewart CUM#ERRLAND COUNTY Solicitor PENNSYLVANIA The Estate of Mary Frances Walsh, Deceased by her Executor, Ronald J. Case Number VS. James F. Rich, M17 (et al.) 2012-5043 SHERIFF'S RETURN OF SERVICE 08/1512012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Pinnacle Health Medical Group, Inc., but was unable to Inte them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint and Notice according to law. 08/17/2012 12:3§ PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August 17, 2P12 at 1236 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: James F. Rich, MD, by making known unto Michelle Joynt, Housekeeper for James F. Rich, !MD and adult in charge at 4 Conestoga Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. f, TSHALL, D UTY 08/17/2012 12:3Q PM - Shawn Gutshall, Deputy Sheriff, who being duly swam according to law, states that on August 17, 2p12 at 1236 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: James F. Rich, MD, PC, by making known unto Michelle Joynt, Housekeeper for James F. Ri h, MD, PC and adult in charge at 4 Conestoga Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. S ALL, DEPUTY- 08/17/2012 01:10 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August 17, 12 at 1310 hours, he served a true copy of the within Complaint and Notice, upon the within named defe dant, to wit: Kenneth B. Conner, MD, by making known unto Krys Vogelsong, Patient Services Rep sentative for Conner, Kusztos Associates at 207 House Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy; of the same. TSHALL, EPLITY 08/17/2012 01:10 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August 17, 012 at 1310 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Conner, Kusztos Associates, by making known unto Krys Vogelsong, Patient Services Representative for Conner, Kusztos Associates at 207 House Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. (c) CountySuite Sheriff, Teleosoft, Inc. 4e?? ?/- ? A D UTY 08/17/2012 01:39 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August 17, 2012 at 1339 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Heritage Medical Group, LLC, by making known unto Deborah Banks, Administrative Assistant for Heritage Medical Group, LLC at 3 Walnut Street, Room 206, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. TSHALL, EPUTY 08/20/2012 09:201AM - Dauphin County Return: And now August 20, 2012 at 0920 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Pinnacle Health Medical Group, Inc. by maki known unto Phyllis Plank, Risk Management Coordinator for Pinnacle Health Medical Group, Inc. at 40 S. Second Street, Suite 2C, Harrisburg, Pennsylvania 17105 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $165.90 August 29, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. the J64,%rr-ff Shelley Ruhl Real Esta e Deputy William T. Tully Solicitor Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER EXECUTOR, RONALD J. WALSH VS PINNACLE HEALTH MEDICAL GROUP, INC. Sheriff s Return No. 2012-T-2276 OTHER COUNTY NO. 2012-5043 And now: AUGUST 20, 2012 at 9:20:00 AM served the within NOTICE & COMPLAINT upon PINNACLE HEALTH MEDICAL GROUP, INC. by personally handing to PHYLLIS PLANK I true attested copy of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 409 S. SECOND STREET, SUITE 2C HARRISBURG PA 17105 RISK MANAGEMENT COORDINATOR Sworn and subscribed to before me this 21ST day of August, 2012 -)P?42 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County 4 Commission Expires August 17, 2014 So Answers, X?7e'; Sheriff of phin County, Pa. By " Depu Sheriff' Deputy: JEREMY KABLE Sheriffs Costs: $41.25 8/17/2012 t • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA The Estate of MARY FRANCIS WALSH, Deceased, by her Executor, Ronald J. Walsh, Plaintiff Docket No. 12-5043 CIVIL ACTION - LAW V. JAMES F. RICH, M.D; KENNETH B. CONNER M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants. JURY TRIAL DEMANDED rTICO ZM O C-) , n uz x> c-) t -. Y ? f?J ENTRY OF APPEARANCE Kindly enter the appearance of the undersigned counsel on behalf of Defendant Heritage Medical Group, LLC formerly t/d/b/a Rich Conner Associates. All papers should be served at 17 North Second Street, 16th Floor, Harrisburg, Pennsylvania, 17011. STEVENS & LEE, P.C. Date: October 12, 2012 By: Michael D. Pipa, Esquire Attorney I.D. No. 53624 Karen E. Minehan, Esquire Attorney I.D. No. 78050 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717) 255-7376 (610) 371-7743 (facsimile) mdp@stevenslee.com kem@stevenslee.com Counsel for Defendants 1 SL I 1187440v l 041199.00643 CERTIFICATE OF SERVICE I, Erika L. Montgomery, an employee of Stevens & Lee, P.C., certify that on this date, I served a certified true and correct copy of the foregoing document upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Neil J. Rovner, Esquire Angino & Rovner, P.C. 4503 N. Front Street Harrisburg, PA 17110 Date: October 12, 2012 2 SL I 1187440v 1 041199.00643 C-- Stevens&Lee,P.C. Michael D.Pipa,Esquire-I.D.Number 53624 : 17 North Second Street, 16th Floor Harrisburg,PA 17101 (717)255-7376 mdp@stevenslee.com Attorneys for Defendants THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, DECEASED, BY HER CUMBERLAND COUNTY, EXECUTOR, RONALD J. WALSH, PENNSYLVANIA Plaintiff, NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY JAMES F. RICH,M.D., KENNETH B. ACTION CONNER, M.D., and HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a JURY TRIAL DEMANDED RICH CONNER ASSOCIATES, Defendants. 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, Defendant 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 was sought to be served, 2. a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, 3. Plaintiff s counsel has no objection to the subpoena as evidenced in the attached email correspondence, 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. SL 1226534v1 041199.00644 STEVENS & LEE E Date: March 26 2013 BY 4''`� Michael D. Pipa, Esquire 17 North Dd Street,}16t'Floor Harrisburg,PA 17101 (717) 255-7376 Attorneys for Defendants SL 1 1226534v 1 041199.00644 Boger, Pam L From: Heiman, Katelyn <khelman@angino-rovner.com> Sent: Monday, March 25, 2013 12:44 PM To: Boger, Pam L. Cc: Cathi Wilson-Vugrinic Subject: Walsh v.James F. Rich, M.D.,et al. Hi Pam, We are okay with waiving the 20 day waiting period for Dr. Renu's records that you plan on subpoenaing. Thanks, Katelyn K atefyn Yfefman, (Pa.C.T. Medical Malpractice Paralegal to, Neil I Rovner, Esquire and Lisa M. Benzie, Esquire Angino &Rovner, P.C. 4503 North Front Street Harrisburg,PA 17110 (717) 238-6791 (717) 238-5610 - fax khelman&awn gino-rovner.com Save a tree. Don't print this e-mail unless it's necessary. STEVENS & LEE LAWYERS&CONSULTANTS 17 North Second Street 16th Floor Harrisburg,PA 17101 (717)234-1090 www.stevenslee.com Direct Dial: (717)255-7368 Email: plb@stevenslee.com Direct Fax: (610)371-7751 March 21,2013 Neil J. Rovner,Esquire Angina &Rovner,P.C. 4503 N. Front Street Harrisburg, PA 17110 Re: Walsh Estate v. Rich,M.D., et al Dear Mr. Rovner: Enclosed is Defendant's Notice of Intent to Service of Subpoenas for records from Renu Joshi,M.D. Please see the subpoena for the documents being sought. If you have no objections to the issuance of the subpoena,please let us know as soon as possible, in writing,that(a) you have no objection to the issuance of the subpoena and that (b) you are willing to waive the twenty(20)notice period. Please be advised that the Prothonotary will not accept a letter stating only that you have no objections to the issuance of the subpoena as waiver of the twenty(20)day period. We will provide you with copies of any records we receive in response at your request. Sincerely, STEVENS & LEE f kaki� elm Pamela L. Boger��/ Paralegal /plb Enclosure Philadelphia • Reading • Valley Forge • Lehigh Valley • Harrisburg • Lancaster • Scranton Wilkes-Barre • Princeton • Cherry Hill • New York • Wilmington A PROFESSIONAL CORPORATION SLI 12110243 041199.00644 THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, DECEASED, BY HER CUMBERLAND COUNTY, EXECUTOR, RONALD J.WALSH, PENNSYLVANIA Plaintiff, NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY JAMES F. RICH,M.D.,KENNETH B. ACTION CONNER,M.D., and HERITAGE MEDICAL GROUP,LLC formerly t/d/b/a JURY TRIAL DEMANDED RICH CONNER ASSOCIATES, Defendants. NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants intend 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 any objection to the subpoenas. If no objection is made,the subpoenas may be served. STEVENS & LEE Date: March 21,2013 By Michael D. Pipa, Esquire Attorney I.D.No. 53624 17 North Second Street, 16th Floor Harrisburg,PA 17101 (717)255-7376 (610) 371-7743 mdp@stevenslee.com Attorneys for Defendants SLI 1211020v3 041199.00644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA The Estate of MARY FRANCES WALSH, Deceased, Docket No. 12-5043 by her Executor, Ronald J. Walsh, Plaintiff CIVIL ACTION—LAW V. JURY TRIAL DEMANDED JAMES F. RICH, M.D; KENNETH B. CONNER M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES Defendants. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Renu Joshi, M.D. Harrisburg Hospital 205 S Front Street, Suite A Harrisburg,PA 17104 Within twenty(20)days after service of this subpoena,you are ordered by the court to produce to STEVENS&LEE,17 North Second Street, 16'h Floor,Harrisburg,PA 17101,ATTN: Pamela L. Boger,Paralegal,the following documents or things: Your complete file concerning Mary Frances Walsh(DOB 09/15/34: SSN:xxx-xx-8631) including, but not limited to: all records including chart notes,consults,progress notes,physician's orders,nurses notes,radiology reports, labs,correspondence,electronic messages,telephone messages, reports of all kinds, a patient financial ledger report(billing/payment records),and everything else you maintain concerning this patient. legible conies of the documents or produced thing You may deliver or mail le,,,a things requested by this subpoena,toge&r 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 and reproducing the things sought. If you fail to produce the documents or things requires 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 re%nest of the following person: Michael D. Pipa,Esquire, Stevens &Lee, 17 North Second Street. 16 Floor,Harrisburg,PA, 17101,Court ID# 53624. Attorn efenci zit -7 BY THE COURT: Dater% By: (Prothonptary) t Seal1f SL I 1208066v1 041199,00644 CERTIFICATE OF SERVICE I,PAMELA L. BOGER,PARALEGAL AND EMPLOYEE OF STEVENS &LEE,P.C., HEREBY CERTIFY that a copy of the foregoing document was served by first class mail, postage prepaid,on the 21 st day of March, 2013, upon the following: Neil J. Rovner,Esquire Angino &Rovner,P.C. 4503 N. Front Street Harrisburg,PA 17110 Counsel for Plaintiff C) SLI 1211020v3 041199.00644 CERTIFICATE OF SERVICE 1, Pamela L. Boger, Paralegal,and employee of Stevens&Lee,P.C.,hereby certify that a true and correct copy of the foregoing Certificate Prerequisite to Service of Subpoenas was served upon the following counsel of record,by depositing the same in the United States mail,postage pre-paid, on March 26, 2013 addressed as follows: Neil J. Rovner,Esquire Angino&Rovner,P.C. 4503 N. Front Street Harrisburg,PA 17110 Counsel for Plaintiff U SL 12265340 041199.00644 1 ,r 1 ' E PRO T liar(} '- ANGINO&ROVNER,P.C. LO 13 r j ' PI t 1 Neil.1.Rovner Attorney ID# : 2210$ CUMBERLAND i 4503 North Front Street ��3YL��j,r t Harrisburg,PA 17110-1708 (717)238-6791 - FAX(717)238>5610 Attorneys for Plaintiff(s) E-mail:tirovner @angino-rovner.com THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, DECEASED, BY HER CUMBERLAND COUNTY, PA EXECUTOR, RONALD J. WALSH, Plaintiff NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH JURY TRIAL DEMANDED CONNER ASSOCIATES, Defendants PLAINTIFFS' MOTION FOR STATUS..CONFERENCE AND NOW comes the Plaintiff by and through his attorney and files this Motion for a Status Conference, and in support thereof aver: 1. The Complaint in this case was filed on August 14, 2012. 2. Service upon Defendants James F. Rich, M.D., James F. Rich, M.D., F.C., Kenneth B. Connor, M.D., Connor,Kusztos.Associates and Heritage Medical Group, LLC was effectuated by August 17, 2012. Service upon Defendant Pinnacle,Health Medical Group, Inc. was effectuated by August 20, 2012. 3. On October 8, 2012, an Order was entered by this Court dismissing all claims against Defendant James F. Rich, M.D., P.C. and simplifying the captioned Defendants to James F. Rich, M.D., Kenneth B. Connor, M.D. and Heritage Medical Group, LLC formerly t/d/b/a Rich Connor Associates, which is reflected in the caption above. 526258 4. The Parties have engaged in and have completed written discovery. 5. Depositions are in the process of being scheduled in this'case. 6. Counsel estimate that the trial will take no more than four to five days. 7. Counsel for Plaintiff believes it is in all parties' interests to have the Court set deadlines for the completion of all discovery, the exchange of expert reports and also set a date or term for trial. 8. The Plaintiff is represented by Neil J. Rovner, Esq., of Angina &Rovner, P.C., 4503 N. Front Street,Harrisburg, PA 17110 (717) 238-6791. 9. Defendants James F. Rich, M.D., Kenneth B. Connor, M.D. and Heritage Medical Group, LLC formerly t/d/b/a Rich Connor Associates are represented by Michael D. Pipa, Esquire and Karen E. Minehan, Esquire of Stevens & Lee, P.C., 17 N. Second St., 16'h Floor, Harrisburg, PA 17101, (717) 255-7376. WHEREFORE, the Parties respectfully request that this Honorable Court schedule a status conference. Respectfully submitted, ANGINIO & OyNER, P.C. r squire PA DI' . 2 108 4 FrAtStreet I isburg,Z PA 17110 7 7) 238-6791 nr .vner@angino-rovner.com Date: C5— v3 Counsel for Plaintiff(s) 526258 CERTIFICATE OF SERVICE AND NOW, this as" day of 2013, I, Katelyn Helman, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of this MOTION FOR STATUS CONFERENCE upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael D. Pipa; Esquire Karen E. Minehan, Esquire Stevens &Lee, P.C. 17 North Second Street, 16th-Floor Harrisburg, PA 17101 Counsel for James F. Rich, M.D., Kenneth B. Connor, M.D. and Heritage Medical Group, LLC,formerly t/d/b/a Rich Connor Associates Kate n man, Paralegal Dated: —�a—I 526258 ANGINO&ROVNER,P.C. Neil J.Rovner Attorney ID# : 22108 4503 North Front Street Harrisburg,PA 17110-1708 (717)238-6791 FAX(717)238-5610 Attorneys for Plaintiff(s) E-mail:nrovner @angin6=rovner.com THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALS111, DECEASED, BY HER CUMBERLAND COUNTY, PA EXECUTOR, RONALD J. WALSH, Plaintiff NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JAMES F. RICH, M.D; KENNETH B. CONNER, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH JURY TRIAL DEMANDED CONNER ASSOCIATES, Defendants ORDER AND NOW, this G day of tJ dd AIZ , 2013, upon consideration of Plaintiff's Motion For Status Conference, IT IS HEREBY ORDERED that a Status Conference in this matter is scheduled to begin the �7 . day Of `"'e- , 2013, at � 3d o'clock (A*9p.m.) in Courtroom No. '005 , before the Honorable yd 6 BY THE T: :T: C5" .� r CJ "L7 p-6 P.C--) *° Q 6+7 - rn Distribution on on followin page: �- 526258 J. Distribution: eil J. Rovner, Esquire, Angino & Rovner, P.C., 4503 N. Front Street, Harrisbur P ph# (717) 238-6791, nrovner @angino-rovner.com, Counsel for Plaintiffs g' A 17110; chael D. Pipa, Esq., and Karen E. Minehan, Esq. of Stevens & Lee, P.C., 17 N. Second Street, 16th Floor, Harrisburg, PA 17101, ph# (717) 255-7376, mdp @stevenslee.com, kem @stevenslee.com, Counsel for Defendants James F. Rich, M.D., Kenneth B. Connor, M.D. and Her. tage Medical Group, LLC formerly t/d/b/a Rich Conner Associates «s t P f 3 526258 THE ESTATE OF MARY FRANCES WALSH, IN THE COURT OF COMMON PLEAS OF DECEASED, BY HER EXECUTOR, CUMBERLAND COUNTY, PENNSYLVANIA RONALD J. WALSH, Plaintiff VS NO. 12-5043 c JAMES F. RICH, M. D. ; KENNETH B. z M C: CONNOR M. D. ; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a -<> C RICH CONNER ASSOCIATES, CIVIL ACTION - LAVIZp �- Defendant > x C) -�- -y Cam-. �4 IN RE: STATUS CONFERENCE ORDER OF COURT AND NOW, this 27th day of June, 2013, by agreement of the parties, it is hereby ordered and directed as follows : 1 . All discovery in this case shall be completed by January 2, 2014 . 2 . Plaintiff ' s expert reports must be produced by February 28, 2014 . 3 . The Defendant ' s expert reports must be produced by April 30, 2014 . 4 . If either party desires to file diapositive motions, all such motions must be filed no later than May 30, 2013 . As soon as the 2014 calendar has been published, we will, upon application and agreement of the parties, attach them for a specific trial term. By the Co t— Edward E. Guido, J. ✓ Neil Rovner, Esquire FF Plaintiffs Michael D. Pi pa, Esquire P � q For Defendants :mlc c LLL FILED-OFFICE Stevens&Lee,P.C. ' THE PRO THOP4o Michael D.Pipa,Esquire-I.D.Number 53624 T�It Y 17 North Second Street, 16th Floor 2013 JUL —3 A� 1 j: 26 Harrisburg,PA 17101 (717)255-7376 CUMBERLAND COUNTY mdp @stevenslee.com PENNSYLVANIA Attorneys for Defendants THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, DECEASED, BY HER CUMBERLAND COUNTY, EXECUTOR, RONALD J. WALSH, PENNSYLVANIA Plaintiff, NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY JAMES F. RICH, M.D., KENNETH B. ACTION CONNER,M.D., and HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a JURY TRIAL DEMANDED RICH CONNER ASSOCIATES, Defendants. 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, Defendant 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 was sought to be served, 2. a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, 3. Plaintiff s counsel has no objection to the subpoena as evidenced in the attached correspondence, 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. SL 1 1244139v 1 041199.00644 A?c ngino-rovner 4503 NORTH FRONT STREET RICHARD C.ANGINO NEIL J. ROVNER HARRISBURG,PA 17110-1799 DAVID L.LUTZ MICHAEL E.KOSIK PHONE:(717)238-6791 RICHARD A.SADLOCK LISA M.BENZIE FAX: (717)238-5610 DARYL E.CHRISTOPHER KRISTEN N.SINISI www.angino-rovner.com E-mail: nrovner @angino-rovner.com June 25, 2013 Pam Boger, Paralegal Stevens & Lee, P.C. 17 North Second Street, 16th Floor Harrisburg, PA 17101 VIA EMAIL at plb(aD-stevenslee.com Re: Estate of Mary F. Walsh v. Heritage Medical Center, et al. Dear Pam, Per your correspondence dated June 20, 2013, we have no objection to the issuance of subpoena per Defendant's Notice of Intent to Serve of Subpoenas for records from George W. Kunkel, M.D. We are also willing to waive the twenty (20) day notice period for same. Please let me know if you have any questions or concerns. 4. vner o r , NJ R/cwv 528905 STEVENS & LEE Date: July 2, 2013 By A� Michael D. Pipa, Esquire Attorney ID# 53624 17 North 2nd Street, 16"'Floor Harrisburg, PA 17101 (717) 255-7376 Attorneys for Defendants SL 1 1244139v 1 041199.00644 STEVENS & LEE LAWYERS&CONSULTANTS 17 North Second Street 16th Floor Harrisburg,PA 17101 (717)234-1090 www.stevenslee.com Direct Dial: (717)255-7368 Email: plb@stevenslee.com Direct Fax: (610)371-7751 cart June 20, 2013 O Neil J. Rovner, Esquire Angino & Rovner, P.C. L16J 4503 N. Front Street ••J Harrisburg, PA 17110 Mom LJ.. Re: Walsh Estate v. Rich,M.D., et al Dear Mr. Rovner: Enclosed is Defendant's Notice of Intent to Service of Subpoenas for records from George W. Kunkel, M.D. Please see the subpoena for the documents being sought. If you have no objections to the issuance of the subpoena,please let us know as soon as possible, in writing,that(a) you have no objection to the issuance of the subpoena and that (b) you are willing to waive the twenty (20) notice period. Please be advised that the Prothonotary will not accept a letter stating only that you have no objections to the issuance of the subpoena as waiver of the twenty (20) day period. We will provide you with copies of any records we receive in response at your request. Sincerely, STEVENS & LEE �Mua A- elm Pamela L. Boger Paralegal /plb Enclosure Philadelphia • Reading • Valley Forge • Lehigh Valley • Harrisburg • Lancaster • Scranton Wilkes-Barre • Princeton Cherry Hill • New York • Wilmington A PROFESSIONAL CORPORATION SL1 12110244 041199.00644 THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, DECEASED, BY HER CUMBERLAND COUNTY, EXECUTOR,RONALD J. WALSH, PENNSYLVANIA Plaintiff, NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY JAMES F. RICH, M.D., KENNETH B. ACTION CONNER,M.D., and HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a JURY TRIAL DEMANDED RICH CONNER ASSOCIATES, Defendants. NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants intend 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 any objection to the subpoenas. If no objection is made,the subpoenas may be served. STEVENS &LEE Date: June 20, 2013 By Michael D. Pipa, Vsquilre Attorney I.D.No. 53624 17 North Second Street, 16th Floor Harrisburg,PA 17101 (717)255-7376 (610) 371-7743 mdp @stevenslee.com Attorneys for Defendants SLl 12110200 041199.00644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA The Estate of MARY FRANCES WALSH,Deceased,by her Docket No. 12-5043 Executor,Ronald J.Walsh, Plaintiff CIVIL ACTION—LAW V. JURY TRIAL DEMANDED JAMES F.RICK M.D;KENNETH B. CONNER M.D.; HERITAGE MEDICAL GROUP,LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Attn: Medical Records George W. Kunkel, M.D. East Shore Medical Center 2405 Linglestown Road Harrisburg,PA 17110 Within twenty(20)days after service of this subpoena,you are ordered by the court to produce to STEVENS & LEE,17 North Second Street,16th Floor,Harrisburg,PA 17101,ATTN: Pamela L.Boger,Paralegal,the following documents or things: Your complete file concerning Mary Frances Walsh(DOB 09/15/34: SSN:xxx-xx-8631)including,but not limited to records including chart notes,consults,progress notes,physician's orders,nurses notes,radiology reports, labs, correspondence,electronic messages,telephone messages,reports of all kinds,a patient financial ledger report (billing/payment records),and everything else you maintain concerning this patient. You may deliver or mail legible copies of the documents or produced 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 of producing the things sought. If you fail to produce the documents or things requires 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: Michael D.Pipa,Esquire,Stevens&Lee, 17 N. 2'd Street, l6tb,Floor.Harrisburg,PA, 17101. Court ID#53624. Attomey&,fi''i!'D'e',f,i'�,tid'ants. BY THE COURT: Date,. l B y: Seal of the Co Wt SL 1208066v 041199.00644 CERTIFICATE OF SERVICE I, PAMELA L. BOGER, PARALEGAL AND EMPLOYEE OF STEVENS &LEE, P.C., HEREBY CERTIFY that a copy of the foregoing NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2 1, was served by first class mail,postage prepaid, on the 20th day of June, 2013, upon the following: Neil J. Rovner, Esquire Angino &Rovner, P.C. 4503 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff P—v' o� Pamela L. Boger, aralegal SL1 12110200 041199.00644 r CERTIFICATE OF SERVICE I, Pamela L. Boger, Paralegal, and employee of Stevens& Lee, P.C., hereby certify that a true and correct copy of the foregoing Certificate Prerequisite to Service of Subpoenas was served upon the following counsel of record, by depositing the same in the United States mail, postage pre-paid, on July 2, 2013 addressed as follows: Neil J. Rovner, Esquire Angino & Rovner, P.C. 4503 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff �O SL 1 124413 9v 1 041199.00644 STEVENS & LEE, P.C. _it Michael D. Pipa, Esquire Attorney I.D. No. 53624 ; ", 31 M f Karen E. Minehan, Esquire Attorney I.D. No 78050 f , 1 ,p 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717) 255-7376 (610) 371-7743 (fax) mdp @stevenslee.com kem @stevenslee.com Counsel for Defendants IN THE COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA • The Estate of MARY FRANCES WALSH, : Docket No. 12-5043 Deceased, by her Executor, Ronald J. Walsh, • Plaintiff : CIVIL ACTION—LAW v. : JURY TRIAL DEMANDED JAMES F. RICH, M.D.; KENNETH B. CONNER, : M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, : • Defendants. • • • STIPULATION All named parties, by and through their counsel, hereby stipulate and respectfully request that the Court extend the pretrial deadlines that were entered via Order dated June 27, 2013 as follows: 1. All discovery in this case shall be completed by March 2, 2014. 2. Plaintiff's expert reports shall be produced by April 28, 2014. 3. Defendants' expert reports shall be produced by June 30, 2014. 2 SL 1 1276993v1 041199.00644 4. If any party desires to produce dispositive motions, all such motions shall be filed no later than July 30, 2014. 5. Thereafter, any party may file a praecipe directing the Prothonotary to list the case for trial pursuant to Cumb. R.Civ. P. 214-1. 6. The Stipulation may be executed in counterparts and shall be considered effective when signed by all counsel even though signed on separate signature pages. 7. All counsel certify that they have authorization to execute the Stipulation on behalf of their respective clients and that they authorize the filing of any non-original facsimile or other copy of the present Stipulation. See Pa.Rule Civ.P. 205.3. 8. The parties, by their respective counsel, have caused this Stipulation to be executed and intend to be legally bound thereby. ANGINO &ROVNER, P.C. / ' / l Date: /7Pd , 2013 By: G Neil J. Rovner, Esq 're 4503 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff STEVENS & LEE, P.C. Date: ( 3U , 201_ By: \` Michael D. Pipa, Esquire Attorney I.D.No. 53624 Karen E. Minehan, Esquire Attorney 1.D. No. 78050 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717)255-7376 (610) 371-7743 (facsimile) mdp @stevenslee.com Counsel for Defendants 3 SL1 1276993v1 041199.00644 CERTIFICATE OF SERVICE I, Erika L. Montgomery, an employee of Stevens & Lee, P.C., certify that on this date, I served a certified true and correct copy of the foregoing document upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Neil J. Rovner, Esquire Angino & Rovner, P.C. • 4503 North Front Street Harrisburg, PA 17110 Weed Date: \ C-J0,ab(3 SL 1 1276993v! 041199.00644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA The Estate of MARY FRANCES WALSH, : Docket No. 12-5043 Deceased, by her Executor, Ronald J. Walsh, : Plaintiff : CIVIL ACTION—LAW V. JURY TRIAL DEMANDED JAMES F. RICH, M.D.; KENNETH B. CONNER M.D.; HERITAGE MEDICAL : : GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, - ' • Defendants. ORDER AND NOW,this 3liay oft-hiAlitda, 2014, upon consideration of the Stipulation of Counsel, it is hereby ORDERED and DECREED that 1. All discovery in this case shall be completed by March 2, 2014. 2. Plaintiffs expert reports shall be produced by April 28, 2014. 3. Defendants' expert reports shall be produced by June 30, 2014, 4. If any party desires to produce dispositive motions, all such motions shall be filed no later than July 30, 2014. 5. Thereafter, any party may file a praecipe directing the Prothonotary to list the case for trial pursuant to Cumb. R.Civ. P. 214-1. The Court shall attach the parties and counsel for a specific trial term. B HE CO T: vita J. Distribution list on following page: SL I 1276993v1 041199.00644 • Distri ution List: Neil J. Rovner, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Michael D. Pipa, Esquire Stevens & Lee, P.C. 17 North Second Street, 16th Floor Harrisburg, PA 17101 C.CT LIES f .1 L€CL /t y p 7T-nt) SL1 1276993v1 041199.00644 Stevens&Lee,P.C. Tr'r,.,,E�'�" r F,.;O T ii.� Michael D.Pipa,Esquire-I.D.Number 53624 17 North Second Street, 16th Floor �U 1 F�B z Harrisburg,PA 17101 Pr �' 43 (717)255-7376 , fi y'r mdp @stevenslee.c6m ENt�s}'(��OUST? Attorneys for Defendants THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, DECEASED, BY HER CUMBERLAND COUNTY, EXECUTOR, RONALD J. WALSH, PENNSYLVANIA Plaintiff, NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY JAMES F. RICH, M.D., KENNETH B. ACTION CONNER, M.D., and HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a JURY TRIAL DEMANDED RICH CONNER ASSOCIATES, Defendants. 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, Defendant 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 was sought to be served, 2. a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, 3. Plaintiff's counsel has no objection to the subpoena, 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. SL 1 1284981 v 1 041199.00644 STEVENS & LEE � 1\ Date: February 2014 By \mi C�'a . P�� Michael D. Pipa, Esquire Attorney ID# 53624 17 North Second Street, 16`h Floor Harrisburg, PA 17101 (717) 255-7376 mdp @stevenslee.com Attorneys for Defendants SL 1 1284981 v 1 041199.00644 STEVENS & LEE LAWYERS&CONSULTANTS 17 North Second Street,16th Floor Harrisburg,PA 17101 (717)234-1090 www.stevenslee.com Direct Dial: (717)255-7368 Email: plb@stevenslee.com Direct Fax: (610)371-7751 January 20, 2014 Neil J. Rovner, Esquire Angino &Rovner, P.C. 4503 N. Front Street Harrisburg, PA 17110 Re: Walsh Estate v. Rich, M.D., et al Dear Mr. Rovner: Enclosed is Defendant's Notice of Intent to Service of Subpoenas for records from Grandview Surgery & Laser Center. Please see the subpoena for the documents being sought. If you have no objections to the issuance of the subpoena,please let us know as soon as possible, in writing, that(a) you have no objection to the issuance of the subpoena and that (b) you are willing to waive the twenty (20) notice period. Please be advised that the Prothonotary will not accept a letter stating only that you have no objections to the issuance of the subpoena as waiver of the twenty(20) day period. We will provide you with copies of any records we receive in response at your request. Sincerely, STEVENS &LEE fMMW4F1 e lm Pamela L. Boge Paralegal /plb Enclosure Philadelphia Reading • Valley Forge • Lehigh Valley • Harrisburg • Lancaster • Scranton Wilkes-Barre • Princeton • Cherry Hill • New York • Wilmington A PROFESSIONAL CORPORATION SL1 12110245 041199.00644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA THE ESTATE OF MARY FRANCES WALSH, DECEASED, BY HER Docket No. 12-5043 EXECUTOR, RONALD J. WALSH, CIVIL ACTION - LAW Plaintiff, JURY TRIAL DEMANDED V. JAMES F. RICH, M.D., KENNETH B. CONNER, M.D., and HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants. NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendants intend 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 any objection to the subpoena. If no objection is made,the subpoena may be served. STEVENS & LEE Date: January 20, 2014 By Jn. w0, Michael D. Pipa, Vsquire Attorney I.D.No. 53624 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717)255-7376 (610) 371-7743 mdp @stevenslee.com Attorneys for Defendants SL 112798541041199.00644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA The Estate of MARY FRANCES WALSH,Deceased,by Docket No. 12-5043 her Executor,Ronald J.Walsh, Plaintiff CIVIL ACTION—LAW V. JURY TRIAL DEMANDED JAMES F.RICH, M.D;KENNETH B. CONNER M.D.; HERITAGE MEDICAL GROUP,LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUL.E.4009.22 - TO: Grandview Surgery & Laser Center 205 Grandview Ave Camp Hill, PA 17011 Within twenty(20)days after service of this subpoena,you are ordered by the court to produce to STEVENS & LEE, 17 North Second Street, 16'h Floor,Harrisburg,PA 17101,ATTN: Pamela L.Boger,Paralegal,the following documents or things: Your complete file concerning Mary Frances Walsh(DOB 09/15/34: SSN:xxx-xx-8631)including,but not limited to: all inpatient, outpatient, same day surgery,physical therapy, occupational therapy,pain management,visiting home nurse or rehabilitation, and ED records, including admission/discharge, consults, progress notes,physician's orders, nurses notes,radiology reports, labs, correspondence, electronic messages,telephone messages,reports of all kinds, a patient financial ledger report(billing/payment records), and everything else you maintain concerning this patient, including any and all cardiac diagnostic studies performed, including EKG's. You may deliver or mail legible copies of the documents or produced 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 pr producing the things sought. If you fail to produce the documents or things requires 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: Michael D.Pipa,Esq., Stevens &Lee,P.C., 17 North Second Street, 16th Floor,Harrisburg,PA 17101, Court ID# 53624. Attorneys for Defendants. BY THE COURT: Date: t . �! By: (Prothonotary) Seal of the C-P-a t , SL 1 12798 56v 1 041199.00644 CERTIFICATE OF SERVICE I, ERIKA L. MONTGOMERY, EMPLOYEE AT STEVENS &LEE, P.C., certify that a copy of the foregoing NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21, was served by first class mail, postage prepaid, on the 20th day of January, 2014, upon the following: Neil J. Rovner, Esquire Angino & Rovner, P.C. 4503 N. Front Street Harrisburg,PA 17110 SL 1 12798540 041199.00644 CERTIFICATE OF SERVICE I, Erika L. Montgomery, and employee of Stevens & Lee, P.C., hereby certify that a true and correct copy of the foregoing Certificate Prerequisite to Service of Subpoenas was served upon the following counsel of record, by depositing the same in the United States mail, postage pre-paid, on February 11, 2014 addressed as follows: Neil J. Rovner, Esquire Angino & Rovner, P.C. 4503 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff SL 1 1284981 v 1 041199.00644 ANGINO & LUTZ, P.C. Richard C. Angino Attorney ID# 07140 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com Eb-OrNCE OF THE PROTHONOTARY 2014 APR 25 A14 CUMBERL ANC) COUNTY PENNSYLVANIA - THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 12-5043 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Richard C. Angino, Esquire, for the firm of Angino & Lutz, P.C., on behalf of Ronald J. Walsh, as Executor of the Estate of Mary F. Walsh in the above action. Notice by copy hereof is given to all counsel of record. ANGINO & Date: April 24, 2014 551356 UTZ, P.C. Pe' lard C. Ang o, Esquire P I.D. No. 0 40 4 03 N. Fr t Street Harrisb g, PA 17110 (717) 238-6791 rca@anginolutz.com Attorney for Plaintiff CERTIFICATE OF SERVICE I, Martie A. Manno, an employee of the law firm of Angino & Lutz, P.C., do hereby certify that I am this day serving a true and correct copy of the foregoing upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael D. Pipa, Esquire Karen E. Minehan, Esquire Stevens & Lee, P.C. 17 North Second Street 16th Floor Harrisburg, PA 17101 Counsel for Defendant Heritage Medical Group, LLP formerly t/d/b/a Rich Conner Associates Date: April 24, 2014 551356 Mrtie A. Manno, Pa aleg STEVENS & LEE, P.C. Michael D. Pipa, Esquire Attorney I.D. No. 53624 Karen. E. Minehan, Esquire Attorney I.D. No. 78050 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717) 255 -7376 (610) 371 -7743 (fax) mdp @stevenslee•com kem @stevenslee,com Counsel.for Defendants r� 2014 ilPR 30 Fr1 l: vQ 'v UPFNNL ND COU SLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA The Estate of MARY FRANCES WALSH, Deceased, by her Executor, Ronald J. Walsh, Plaintiff v. : Docket No, 12 -5043 CIVIL ACTION — LAW : JURY TRIAL DEMANDED JAMES F. RICH, M.D,; KENNETH B. CONNER, : M.D.; HERITAGE MEDICAL GROUP, LLC : formerly t /d /b /a RICH CONNER ASSOCIATES, : Defendants. STIPULATION All named parties, by and through their counsel, hereby stipulate and respectfully request that the Court extend the pretrial deadlines that were entered via Order dated June 27, 2013 as follows: 1. Plaintiff's expert reports shall be produced by June 28, 2014. 2. Defendants' expert reports shall be produced by August 30, 2014. 551306 2 SL! 1 298604v 1 041 199.00644 3. If any party desires to produce dispositive motions. all such motions shall be tiled no later than September 30, 2014. 4. '[hereafter, any party may file a praccipe directing the Prothonotary to list the case [or trial pursuant to Cumb. 1:.Civ. P.'214 -1. 5. The Stipulation may be executed in counterparts and shall be considered effective when signed by all counsel even though signed on separate signature pages. 6. All counsel certify that they have authorization to execute the Stipulation on behalf or their respective clients and that the authorize the fling of anv non-original fac.sililile or copy of the present Stipulation. Sec Pa.Rule ('ir .'I'. 7. The parties, by their respective counsel, have caused this Stipulation to be executed and intend to be legally bound thereby. Date: a"'\ , 2014 Date: `i 551306 Lf ,2.014 SI,1 1298601v 011199.00614 ANG[NO & l-,Ul"% P.C. By: Richard -.._( Angino. F.s.quire 4503 North Front Sta`eet llarri`sburg, PA 17,10 Comae! for Plaintiff STEVENS & 11,l2, . P.C. By: \,��._.._ Michael I). Pipa. Esquire :Attorney 1.D. o. Karen l . h'linehan. Esquire Attorney I.D. No. 78050 17 North. Second Street, Kith Floor Harrisburg. PA 17101 (717) 255-7376 (610) 371 -7743 (facsimile) mdp@stevenslec.com Counsel fur Delinu/anIs CERTIFICATE OF SERVICE I, Erika L. Montgomery, an employee of Stevens & Lee, P.C., certify that on this date, I served a certified true and correct copy of the foregoing document upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Date: SL1 1298604v1 041199.00644 Richard C. Angino, Esquire Angino & Lutz, P.C. 4503 North Front Street Harrisburg, PA 17110 NARITSKV, OLSON & WISNESKI, LLP Neil J. Rovner, Esquire Attorney 11D4 : 22108 2040 Linglestown Road, Suite 303 Harrisburg, PA 17110 (717) 541-9205 Attorneys for Plaintiff(s) E-mail: nrovner@nowl1p.com Pio '2044 30 13,11 1: Ulla I. 4 Ps,vo CO UNT ANIA THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff V. JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 12-5043 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Neil J. Rovner, Esquire for the firm of Angino & Rayner, P.C., on behalf of Plaintiff Ronald J. Walsh, as Executor of the Estate of Mary F. Walsh, deceased in the above action. Notice by copy hereof is given to all counsel of record. NAVITSKY, OLSON & WISNESKI, LLP Date: April 551311 , 2014 By. N J. Roy -r, !squi Attorney 2108 2040 Ling-town R ad, Suite 303 Harrisburg, PA 17110 (717) 541-9205 nrovner@nowl1p.com Counsel for Plaintiff CERTIFICATE OF SERVICE I, Katelyn M. Helman, an employee of the law firm of Navitsky, Olson & Wisneski, LLP, do hereby certify that I am this day serving a true and correct copy of the foregoing WITHDRAWAL OF APPEARANCE upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael D. Pipa, Esquire Karen E. Minehan, Esquire Stevens & Lee, P.C. . 17 North Second Street 16th Floor Harrisburg, PA 17101 Counsel for Defendants Date: April (■(-{ , 2014 551311 at lyn M. Helman, Paralegal IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA The Estate of MARY FRANCES WALSH, : Docket No. 12-5043 Deceased, by her Executor, Ronald J. Walsh, Plaintiff : CIVIL ACTION - LAW v. JURY TRIAL DEMANDED JAMES F. RICH, M.D.; KENNETH B. CONNER, : M.D.; HERITAGE MEDICAL GROUP, LLC : formerly t/d/b/a RICH CONNER ASSOCIATES, : Defendants. ORDER AND NOW, this / day of /79,1Y , 2014, upon consideration of the Stipulation of Counsel, it is hereby ORDERED and DECREED that 1. Plaintiff's expert reports shall be produced by June 28, 2014. 2. Defendants' expert reports shall be produced by August 30, 2014. 3. If any party desires to produce dispositive motions, all such motions shall be filed no later than September 30, 2014. 4. Thereafter, any party may file a praecipe directing the Prothonotary to list the case for trial pursuant to Cumb. R.Civ. P. 214-1. The Court shall attach the parties and counsel for a specific trial term. Distribution list on following page. SL1 1298604v1 041199.00644 J. 3 Distribution List: lchard C, Angino, Esquire Angino & Lutz, P.C. 4503 North Front Street Harrisburg, PA 17110 ichael D. Pipa, Esquire Stevens & Lee, P.C. 17 North Second Street, 16th Floor Harrisburg, PA 17101. frZtt.s&c.L slal ly 551306 SLI 1298604v1 041 199,00644 f r f7,C�,Lu-OFFICE � 2014 AUG 18 r�r�11: 42 Ute&ERS AND COUNT Y ANGINO & LUTZ, P.C. Richard C. Angino, Esquire Attorney ID# : 07140 Jonathan E. Danko, Esquire Attorney 1D#: 314653 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com jdanko@anginolutz.com THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff v. JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 12-5043 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PLAINTIFF'S PETITION TO WITHDRAW AS COUNSEL Richard C. Angino, Esquire and the law firm of Angino & Lutz. P.C., formerly Angino & Rovner, P.C., and as counsel for Plaintiff, The Estate of Mary Frances Walsh, by her Executor, Ronald J. Walsh, respectfully moves this Honorable Court to allow him and Angino & Lutz, P.C. to withdraw their appearance for the following reasons: 555459 1. Plaintiff engaged the Law Firm of Angino & Lutz, P.C. to represent them in this personal injury medical malpractice claim. 2. The instant action was filed by a Complaint on August 14, 2012, with attached certificates of merit. 3. This case involves a medical negligence claim filed against James F. Rich, M.D; Kenneth B. Connor, M.D.; Heritage Medical Group, LLC Formerly t/d/b/a Rich Conner Associates, resulting in personal injury and death to the Plaintiff. 4. Pleadings and discovery have been completed. 5. In filing the Complaint on August 14, 2012, Plaintiffs counsel received a statement of merit from Dr. Robert C. Gorman, M.D., an expert in the field of cardiothoracic surgery. 6. Following pleadings and discovery and in accordance with Court mandated agreed deadlines, Plaintiff's counsel sought a report from Dr. Gorman who declined to be further involved with this matter and was unwilling to provide an expert report. 7. Plaintiff's counsel obtained a second expert, Dr. Gary S. Kopf, M.D., to review the case and provide a statement of merit and an expert report. 8. Dr. Kopf was unwilling to provide counsel with a statement of merit or expert report. 9. By a telephone conference on June 27, 2014, Plaintiff's counsel requested Plaintiff to secure replacement counsel.. 10. At the client's request, Plaintiffs counsel provided all of the medical records at no cost on July 24, 2014. 11. To date, Angino & Lutz, P.C. have not heard from Plaintiff nor any new counsel. 555459 12. Defendants, through their counsel, Stevens & Lee, was provided with a copy of the instant Petition and proposed order via email on August 14, 2014, and concur in this request, a copy of which is attached to this Petition as Exhibit A. 13. Likewise, Counsel for Heritage Medical Group, LLP formerly t/d/b/a Rich Conner Associates, Michael D. Pipa, Esquire and Karen E. Minehan, Esquire, do not object to Angino & Lutz, P.C.'s request to withdraw its appearance as counsel for The Estate of Mary Frances Walsh, by her Executor, Ronald J. Walsh. WHEREFORE, Plaintiff's counsel respectfully requests this Honorable Court allow the undersigned counsel to withdraw as counsel of record on behalf of Plaintiff and permit the Plaintiff a period of not less than sixty (60) additional days to obtain new counsel. Respectfully submitted, ANGINA & UTZ, P.C. Angino, Esquire o. 07140 . Front Street sburg, PA 17110 ) 238-6791 a@anginolutz.com Attorney for Plaintiff Date: August 15, 2014 555459 EXHIBIT Martie Manno From: Minehan, Karen E. <KEM@stevenslee.com> Sent: Friday, August 15, 2014 2:15 PM To: Martie Manno Subject: Re: Walsh v. Rich - Petition to Withdraw Fire away. Sent from my iPhone On Aug 15, 2014, at 2:01 PM, "Martie Manno" <mmaldonado@anginolutz.com> wrote: Mr. Angino does agree with the changes you would like made to the Order. See attached. I will get this filed if now okay with you? From: Minehan, Karen E. [mailto:KEM@stevenslee.com] Sent: Friday, August 15, 2014 10:53 AM To: Martie Manno Subject: RE: Walsh v. Rich - Petition to Withdraw Martie- you can indicate that we do not object to the Plaintiff's counsels petition for leave to withdraw if you amend the attached order as follows: AND NOW, this day of August, 2014, upon consideration of the Plaintiff's Petition to Withdraw as Counsel and for the reasons stated therein, said Petition is hereby GRANTED and Angino & Lutz, P.C. is permitted to withdraw as counsel of record. Angino & Lutz, P.C. shall file a formal Withdrawal of Appearance within ten (10) days of the date of this Order. The Withdrawal of Appearance shall include Plaintiff Ronald J. Walsh's updated contact information, if known. The matter is stayed for sixty (60) days from the date of this Order or until substitute counsel formally enters an appearance for Plaintiff, whichever comes first. This alternate order is identical to yours, but adds clarity about the date of formal withdrawal and the entry of the stay. If Angino Rovner prefers his own order, we can respond to the petition and attach our proposed order. Thank you for your courtesy. From: Minehan, Karen E. Sent: Thursday, August 14, 2014 2:56 PM To: Martie Manno Subject: RE: Walsh v. Rich - Petition to Withdraw I am looking at the petition and will get back to you. Karen "Missy" Minehan STEVENS & LEE A Stevens & Lee/Griffin Company 17 North Second Street, 16th Floor I Harrisburg, PA 17101 Phone: (717) 255-7384 I Internal: 3384 I Fax: (610) 371-7744 KEM@stevenslee.com ( www.stevenslee.com From: Martie Manna [mailto:mmaldonado@anginolutz.com] Sent: Thursday, August 14, 2014 2:14 PM To: Minehan, Karen E. Cc: _RCA Group Subject: Walsh v. Rich - Petition to Withdraw Hello Attorney Minehan: Do you give concurrence to the attached Plaintiff's Petition to Withdraw as Counsel? I plan to file the Motion as soon as we receive your response. Thank you Ma vt't,e'A. Mabio a,d a; Medical Malpractice Paralegal mmaldonado@anginolutz.com Angino & Lutz, P.C. 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791, ext. 3057 www.andinolutz.com The content of this E-mail message is attorney privileged and highly confidential, directed only to the above named person. Therefore, distribution, utilization or copying of this information by anyone other than the designated recipient is strictly prohibited. If you have erroneously received this communication, please notify us immediately at (717) 238-6791, and return the original message to us by E-mail. Thank you. This email may contain privileged and confidential information and is solely for the use of the sender's intended recipient(s). If you received this email in error, please notify the sender by reply email and delete all copies and attachments. Thank you. <555459 1.dotx> This email may contain privileged and confidential information and is solely for the use of the sender's intended recipient(s). If you received this email in error, please notify the sender by reply email and delete all copies and attachments. Thank you. 2 CERTIFICATE OF SERVICE I, Martie A. Maldonado, an employee of the law firm of Angino & Lutz, P.C., do hereby certify that I am this day serving a true and correct copy of the foregoing PLAINTIFF'S PETITION TO WITHDRAW AS COUNSEL upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael D. Pipa, Esquire Karen E. Minehan, Esquire Stevens & Lee, P.C. 17 North Second Street 16th Floor Harrisburg, PA 17101 Counsel for Defendant Heritage Medical Group, LLP formerly t/d/b/a Rich Conner Associates rtie A. Maldonado, P Date: August 15, 2014 555459 legal ANGINO&LUTZ,P.C. Richard C.Angino,Esquire Attorney ID#: 07140 Jonathan E.Danko,Esquire Attorney ID#: 314653 4503 North Front Street Harrisburg,PA 17110-1708 (717)238-6791 FAX(717)238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com jdanko@anginolutz.com THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, BY HER EXECUTOR, CUMBERLAND COUNTY, PA RONALD J. WALSH, Plaintiff NO. 12-5043 V. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH JURY TRIAL DEMANDED CONNER ASSOCIATES, Defendants ORDER AND NOW, this 28TH day of AUGUST, 2014, a Rule is issued on the Plaintiff to Show Cause why Counsel's Petition to Withdraw should not be granted. Rule returnable twenty (20) days after service. By th , Edward E. Guido, J. R�ich�ard C. Angino, Esquire -,- Michael D. Pipa, Esquire :sld �zr u y c-) f >C _ c _ THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff v. JAMES F. RICH,M.D; KENNETH B. CONNOR, K4.[; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CON NER ASSOCIATES, Defendants CIF rfirE PRO '� vu/A/,20/4 SEP /9 Pil U COUI NO. 12-5043 2cn/y The following statement is made to comply with Court Order dated August 24, 2014, by Judge Edward E. Guido, Court of Common Pleas, Cumberland County,Pa.: The Estate of Mary Frances Walsh, Ronald J. Walsh, Executor cannot show just cause why Counsel's Petition to withdraw should not be granted. 47-44,4 Ronald J Walsh, Executor Cc: Richard C. Angino, Esquire Michael D. PipaEsquire Kim McCormick, Estate Spokesperson James V. Walsh �� -° FILF0-0FrifY iEFROT 0 TA n. ti SEP 29 PH 1 CUMBERLAND COUNTY PENNSYLVANIA ANGINO & LUTZ, P.C. Richard C. Angino, Esquire Attorney ID# : 07140 Jonathan E. Danko, Esquire Attorney 1D#: 314653 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com jdanko@anginolutz.com THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff v. JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 12-5043 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED MOTION TO MAKE RULE ABSOLUTE AND NOW come Plaintiff, Ronald J. Walsh, Executor for the Estate of Mary Frances Walsh, deceased, by and through his attorneys, Angino & Lutz, P.C., by Richard C. Angino, Esquire, and hereby move this Court to make its Rule to Show Cause Absolute regarding its Motion to Withdraw as Counsel on behalf of Plaintiff for the following reasons: 1 On August 18, 2014, Plaintiff filed a Petition to Withdraw as Counsel. (Petition attached hereto as Exhibit A.) 2. On August 28, 2014, the Court issued an Order Ruling the Plaintiff to Show Cause why Counsel's Petition to Withdraw should not be granted which was served upon counsel and Plaintiff on September 2, 2014. (Attached hereto as Exhibit B.) 3, The Rule to Show Cause was made returnable twenty (20) days after service. 4. The Rule was, therefore, returnable on September 22, 2014. 5. On September 19, 2014, Plaintiff filed a statement with the Court stating "The Estate of Mary Frances Walsh, Ronald J. Walsh, Executor cannot show just cause why Counsel's Petition to withdraw should not be granted." (Attached hereto as Exhibit C.) 6. Plaintiffs statement was served upon counsel, via regular mail, on September 19, 2014. WHEREFORE, Plaintiff move this Court will make absolute the Rule to Show Cause and the Order attached hereto be executed by the Court for service upon Plaintiff and counsel. Date: September 26, 2014 Respectfully submitted, ANGINO & LUTZ, P.C. 2 i hard C. : gi o, Esquire A I.D. . 0/4140 4503 . Fr•aft Street Ha °sbu:, PA 17110 ( 7} 8-6791 anginolutz.com Attorney for Plaintiffs EXHIBIT A ED- OFFIC;. C.F 1.1:if-PRO T HO N 6 -TA R 2C14 AL1G 18 AN 11: 42 CUMBERLAND COUNTY PENNSYLVANIA ANGINO & LUTZ, P.C. Richard C. Angino, Esquire Attorney ID# 07140 Jonathan E. Danko, Esquire Attorney ID#: 314653 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com jdanko@anginolutz.com THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff v. JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 12-5043 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED. PLAINTIFF'S PETITION TO WITHDRAW AS COUNSEL Richard C. Angina, Esquire and the law firm of Angino & Lutz. P.C., formerly Angino & Rovner, P.C., and as counsel for Plaintiff, The Estate of Mary Frances Walsh, by her Executor, Ronald J. Walsh, respectfully moves this Honorable Court to allow him and Angino & Lutz, P.C. to withdraw their appearance for the following reasons: 555459 1. Plaintiff engaged the Law Firm of Angino & Lutz, P.C. to represent them in this personal injury medical malpractice claim. 2. The instant action was filed by a Complaint on August 14, 2012, with attached certificates of merit. 3. This case involves a medical negligence claim filed against James F. Rich, M.D; Kenneth B. Connor, M.D.; Heritage Medical Group, LLC Formerly t/d/b/a Rich Conner Associates, resulting in personal injury and death to the Plaintiff. 4. Pleadings and discovery have been completed. 5. In filing the Complaint on August 14, 2012, Plaintiffs counsel received a statement of merit from Dr. Robert C. Gorman, M.D., an expert 'in the field of cardiothoracic surgery. 6. Following pleadings and discovery and in accordance with Court mandated agreed deadlines, Plaintiff's counsel sought a report from Dr. Gorman who declined to be further involved with this matter and was unwilling to provide an expert report. 7. Plaintiffs counsel obtained a second expert, Dr. Gary S. Kopf, M.D., to review the case and provide a statement of merit and an expert report. 8. Dr. Kopf was unwilling to provide counsel with a statement of merit or expert report. 9. By a telephone conference on June 27, 2014, Plaintiff's counsel requested Plaintiff to secure replacement counsel. 10. At the client's request, Plaintiff's counsel provided all of the medical records at no cost on July 24, 2014. 11. To date, Angino & Lutz, P.C. have not heard from Plaintiff nor any new counsel. 555459 12. Defendants, through their counsel, Stevens & Lee, was provided with a copy of the instant Petition and proposed order via email on August 14, 2014, and concur in this request, a copy of which is attached to this Petition as Exhibit A. 13. Likewise, Counsel for Heritage Medical Group, LLP formerly t/d/b/a Rich Conner Associates, Michael D. Pipa, Esquire and Karen E. Minehan, Esquire, do not object to Angino & Lutz, P.C.'s request to withdraw its appearance as counsel for The Estate of Mary Frances Walsh, by her Executor, Ronald J. Walsh. WHEREFORE, Plaintiffs counsel respectfully requests this Honorable Court allow the undersigned counsel to withdraw as counsel of record on behalf of Plaintiff and permit the Plaintiff a period of not less than sixty (60) additional days to obtain new counsel. Respectfully submitted, ANGINCy& LUTZ, P.C. chard A LD /)- Angino, Esquire o. 07140 . Front Street sburg, PA 17110 ) 238-6791 a@anginolutz.com Attorney for Plaintiff Date: August 15, 2014 555459 Martie Manno From: Minehan, Karen E. <KEM@stevenslee.com> Sent: Friday, August 15, 2014 2:15 PM To: Martie Manna Subject: Re: Walsh v. Rich - Petition to Withdraw• Fire away. Sent from my iPhone On Aug 15, 2014, at 2:01 PM, "Martie Manno" <mmaldonado@anginolutz.com> wrote: Mr. Angino does agree with the changes you would like made to the Order. See attached. I will get this filed if now okay with you? From: Minehan, Karen E. [mailto:KEMastevenslee.corn] Sent: Friday, August 15, 2014 10:53 AM To: Martie Manno Subject: RE: Walsh v. Rich - Petition to Withdraw Martie- you can indicate that we do not object to the Plaintiff's counsels petition for leave to withdraw if you amend the attached order as follows: AND NOW, this day of August, 2014, upon consideration of the Plaintiff's Petition to Withdraw as Counsel and for the reasons stated therein, said Petition is hereby GRANTED and Angina & Lutz, P.C. is permitted to withdraw as counsel of record. Angino & Lutz, P.C. shall file a formal Withdrawal of Appearance within ten (10) days of the date of this Order. The Withdrawal of Appearance shall include Plaintiff Ronald J. Walsh's updated contact information, if known. The matter is stayed for sixty (60) days from the date of this Order or until substitute counsel formally enters an appearance for Plaintiff, whichever comes first. This alternate order is identical to yours, but adds clarity about the date of formal withdrawal and the entry of the stay. If Angina Rovner prefers his own order, we can respond to the petition and attach our proposed order. Thank you for your courtesy. From: Minehan, Karen E. Sent: Thursday, August 14, 2014 2:56 PM 1 ..�iUiU Subject: RE: Walsh v. Rich - Petition to Withdraw I am looking at the petition and will get back to you. Karen "Missy" Minehan STEVENS & LEE A Stevens & Lee/Griffin Company 17 North Second Street, 16th Floor l Harrisburg, PA 17101 Phone: (717) 255-7384 Internal: 3384 Fax: (610) 371-7744 KEM@stevenslee.com I www.stevenslee.com From: Martie Manno[mailto:mmaidonado(aanginolutz.com] Sent: Thursday, August 14, 2014 2:14 PM To: Minehan, Karen E. Cc: _RCA Group Subject: Walsh v. Rich - Petition to Withdraw .. Hello Attorney Minehan: Do you give concurrence to the attached Plaintiffs Petition to Withdraw as Counsel? I plan to file the Motion as soon as we receive your response. Thank you. 1�1a..frtfe'A. Marva da; Medical Malpractice Paralegal mmaldonado(anginolutz.com Angino_&.,Lutz,:.P.C. 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791, ext. 3057 www.anginolutz.com The content of this E-mail message is attorney privileged and highly confidential, directed only to the above named person. Therefore, distribution, utilization or copying of this information by anyone other than the designated recipient is strictly prohibited. If you have erroneously received this communication, please notify us immediately at (717) 238-6791, and retum the original message to us by E-mail. Thank you. This email may contain privileged and confidential information and is solely for the use of the sender's intended recipient(s). If you received this email in error, please notify the sender by reply email and delete all copies and attachments. Thank you. <555459 1.dotx> This email may contain privileged and confidential information and is solely for the use of the sender's intended recipient(s). if you received this email in error, please notify the sender by reply email and delete all copies and attachments, Thank you. 2 CERTIFICATE OF SERVICE I, Martie A. Maldonado, an employee of the law .firm of Angino & Lutz, P.C., do hereby certify that I am this day serving a true and correct copy of the foregoing PLAINTIFF'S PETITION TO WITHDRAW AS COUNSEL upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael D. Pipa, Esquire Karen E. Minehan, Esquire Stevens & Lee, P.C. 17 North Second Street 16th Floor Harrisburg, PA 17101 Counsel for Defendant Heritage Medical Group, LLP formerly t/d/b/a Rich Conner Associates Date: August 15, 2014 555459 ANGINO & LUTZ, P.C. Richaid C. Angino, Esquire Attorney ID# : 07140 Jonathan E. Danko, Esquire Attorney ID#: 314653 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com jdanko@anginolutz.com THE. ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff v. JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 12-5043 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED ORDER AND NOW, this 28 day of AUGUST, 2014, a Rule is issued on the Plaintiff to Show Cause why Counsel's Petition to Withdraw should not be granted. Rule returnable twenty (20) days after service. ✓Richard C. Angino, Esquire Michael D. Pipa, Esquire :sld 1 Pri' /'C31 lfG�, By th- Edward E. Guido, J. \ J THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff v. JAMES F. RICH,M.D; KENNETH B. CONNOR, M.D; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants NO, 12-5043 4-4ne,07:6645-ie iz ao Ay !LEO OF THE PROTHONO rA /, 2014 SEP 19 P11 1: 5 • CUMBERLAND COUNTY PENNSYLVANIA The following statement is made to comply with Court Order dated August 24, 2014, by Judge Edward E. Guido, Court of Common Pleas , Cumberland County, Pa.: The Estate of Mary Frances Walsh, Ronald J. Walsh, Executor cannot show just cause why Counsel's Petition to withdraw should not be granted. ,„1.2.9 47;41 Ronald 3 Walsh, Executor Cc: Richard C. Angino, Esquire Michael D. Pipa, Esquire Kim McCormick, Estate Spokesperson James V. Walsh CERTIFICATE OF SERVICE I, Martie A. Maldonado, an employee of the law firm of Angino & Lutz, P.C., do hereby certify that I am this day serving a true and correct copy of the foregoing upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael D. Pipa, Esquire Karen E. Minehan, Esquire Stevens & Lee, P.C. 17 North Second Street 16th Floor Harrisburg, PA 17101 Counsel for Defendant Heritage Medical Group, LLP formerly t/d/b/a Rich Conner Associates Date: September 26, 2014 3 (.4/ dial2elai artie A. Maldonado, P alegal • �1 ANGINO&LUTZ,P.C. , Richard C.Angino,Esquire .' R,{ • Attorney ID# : 07140 Jonathan E.Danko,Esquire Attorney ID#: 314653 4503 North Front Street Harrisburg,PA 17110-1708 (717)238-6791 FAX(717)238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com j danko@anginolutz.com THE ESTATE OF MARY FRANCES IN THE COURT OF COMMON PLEAS WALSH, BY HER EXECUTOR, CUMBERLAND COUNTY, PA RONALD J. WALSH, Plaintiff NO. 12-5043 v. CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH JURY TRIAL DEMANDED CONNER ASSOCIATES, Defendants ORDER AND NOW, this ..56-46day of September, 2014, upon consideration of the Plaintiff's Petition to Withdraw as Counsel and for the reasons stated therein, said Petition is hereby GRANTED and Angino & Lutz, P.C. is permitted to withdraw as counsel of record. The matter is stayed for sixty (60) days from the date of this Order or until substitute counsel formally enters an appearance for Plaintiff, whichever comes first. BY THE COURT (° #1#1W J. Distribution List: (see next page) 4 Distribution List: ✓ Richard C. Angino, Esquire Angino & Lutz, P.C. 4503 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff ✓ Michael D. Pipa,Esquire Karen E. Minehan, Esquire Stevens&Lee, P.C. 17 North Second Street 16th Floor Harrisburg, PA 17101 Counsel for Defendants Heritage Medical Group,LLP formerly t/d/b/a Rich Conner Associates Copies Lc.c.L. /0/et//Y Ai 557067 THE PROTHOHO 3Y,i `; 2Qt4OCT 11 PSI 2:3t CUMBERLAND COUNTY PENNSYLVANIA ANGINO & LUTZ, P.C. Richard C. Angino, Esquire Attorney ID# : 07140 Jonathan E. Danko, Esquire Attorney ID#: 314653 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rca@anginolutz.com jdanko@anginolutz.com THE ESTATE OF MARY FRANCES WALSH, BY HER EXECUTOR, RONALD J. WALSH, Plaintiff v. JAMES F. RICH, M.D; KENNETH B. CONNOR, M.D.; HERITAGE MEDICAL GROUP, LLC formerly t/d/b/a RICH CONNER ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 12-5043 CIVIL ACTION MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PRAECIPE TO WITHDRAW AS COUNSEL TO THE PROTHONOTARY: Please withdraw the appearance of Richard C. Angino, Esquire for the firm of Angino & Lutz, P.C., on behalf of Plaintiff Ronald J. Walsh, as Executor of the Estate of Mary F. Walsh, deceased in the above -captioned action. 557850 From this date, please forward all communications directly to Plaintiff Ronald J. Walsh, 7404 Belden Street, Philadelphia, PA 19111 Respectfully submitted, ANGINO & LUTZ, P.C. C. An I.D. No. 4503 N. Fron Street Harrisburg, PA 17110 (717) 238-6791 rca@anginolutz.com Attorney for Plaintiffs Date: October 17, 2014 557850 CERTIFICATE OF SERVICE I, Martie A. Maldonado, an employee of the law firm of Angino & Lutz, P.C., do hereby certify that I am this day serving a true and correct copy of the foregoing PRAECIPE TO WITHDRAW AS COUNSEL upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael D. Pipa, Esquire Karen E. Minehan, Esquire Stevens & Lee, P.C. 17 North Second Street 16th Floor Harrisburg, PA 17101 Counsel for Defendant Heritage Medical Group, LLP formerly t/d/b/a Rich Conner Associates Ronald J. Walsh, Executor Estate of Mary Frances Walsh 7404 Belden Street Philadelphia, PA 19111 Plaintiff M Date: October 17, 2014 557850 A. Maldonado, Paralega IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA The Estate of MARY FRANCES WALSH, : Docket No. 12-5043 Deceased, by her Executor, Ronald J. Walsh, Plaintiff : CIVIL ACTION - LAW v. : JURY TRIAL DEMANDED JAMES F. RICH, M.D.; KENNETH B. CONNER, : M.D.; HERITAGE MEDICAL GROUP, LLC : formerly t/d/b/a RICH CONNER ASSOCIATES, : Defendants. PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above action on the Court docket as discontinued and ended. Respectfully submitted, Date: WC/Sif SL1 133 7398v 1 041199.00644 0-,t,tact 4fatioL Ronald J. Walsh 7404 Belden Street Philadelphia, PA 19111 Pro Se Plaintiff CERTIFICATE OF SERVICE I, Erika Montgomery, employee of Stevens & Lee, certify that on this date, I served a certified true and correct copy of the foregoing document upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Ronald J. Walsh 7404 Belden Street Philadelphia, PA 19111 gdyrtma Date: December 15, 2014