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Andrew C. Spears, Esq.
I.D. # 87737
HANDLER, HENNING & ROSENBERG, LLP n
1300 Linglestown Road ~''~~'~~~R~-ADD COUNi`Y
Harrisburg, PA 17110 ~'~NNSYI.VANIA
Telephone: (717) 238-2000 Attorneys for Plaintiffs
Fax : (717) 233-3029
E-mail: spears@HHRLaw.com
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
WILLIAM TILLMAN and
DEBORAH TILLMAN, his wife - SyU~ ~ v~~
o.. l a
Plaintiffs
v. IVIL ACTION -LAW
JILL R. BRADLEY,
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Complaint and
Notice are served, by entering a written appearance personally or by attorney and filing in writing
with the Court your defenses or objections to the claims set forth against you. You ane warned
that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the Court without further notice for any money claimed in the Complaint or for an
other claim or relief requested by the Plaintiff. You may lose money or property or othher rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NbT HAVE
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CA
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TCD PROVID
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SEI~ViCES T
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990-9108 } ~ 3 .~J~ Q
350
X9975
_ _
_ _ ~
(717) 249-3166
AVISO
I
LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que
se presentan mks adelante en las siguientes pfiginas, debe tomar accibn dentro de Ids prbximos
veinte (20) Bias despu~s de la notificacibn de esta Demanda y Aviso radicando perso~nalmente
por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito su
defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte d
que si usted falla de tomar accibn como se describe anteriormente, el caso puede proceder sin
usted y un fallo por cualquier suma de dinero reclamada en la demanda o cu~lquier otr
reclamacibn o remedio solicitado por el demandante puede ser dictado en contra suya por la Cort
sin mks aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes par
usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTE
NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PLIED
PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES PO$IBLE QU
ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE QFREZCA
SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFIICAN.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800)990-9108
(717) 249-3166
HANDLER, HENNING 8 ROSENBERG, LLP
By:
Andrew C. Spears, Esq.
- _ _ ~
Andrew C. Spears (PA 87737)
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road, Suite 2
Harrisburg, PA 17110
Ph. (717) 238-2000 Attorneys for Plaintiff
Fax (717) 233-3029
spears@hhrlaw.com
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
WILLIAM TILLMAN, and
DEBORAH TILLMAN, his wife,
NO.:
19748 Grove Mill Road
Stewartstown, PA 17363
CIVIL ACTION -LAW
Plaintiffs,
v.
JILL R. BRADLEY,
24 Kim Acres Drive, Floor 2
Mechanicsburg, PA 17055
Defendant.
COMPLAINT
AND Now come the Plaintiffs, William Tillman ("Mr. Tillman") and Deborah Tillm
("Mrs. Tillman"), his wife, by and through their attorneys, HANDLER, HENNING
ROSENBERG, LLP, by Andrew C. Spears, and make the within Complaint against Defendant, Jil
R. Bradley ("Defendant Bradley"), and aver as follows:
1. Mr. Tillman is a competent adult individual currently residing at 19748 Grov
Mill Road, Stewartstown, York County, Pennsylvania.
2. Mrs. Tillman is a competent adult individual currently residing with her husban
at 19748 Grove Mill Road, Stewartstown, York County, Pennsylvania.
3. Defendant Bradley is a competent adult individual with a last known address o
24 Kim Acres Drive, Floor 2, Mechanicsburg, Cumberland County, Pennsylvania.
4. At all times material hereto, Mr. Tillman was a passenger in a 2000 Jee
Cherokee Classic, owned by him and his wife, and operated by Mrs. Tillman, bearin
Pennsylvania registration number FMH0385 ("Tillmans' vehicle").
5. At all times material hereto, Defendant Bradley was the owner and operator of
2006 Toyota Corolla bearing Pennsylvania registration number GKC2548 ("Defendant'
vehicle").
6. At all times material hereto, Mr. Tillman was a named insured under
automobile insurance policy issued by 21st Century Insurance Company under the limited-to
option.
7. Pursuant to 75 Pa. C.S.A. § 1705(d), Mr. Tillman is entitled to recove
noneconomic damages as though he was covered under the full-tort option as Mr. Tillm
sustained a serious injury as a result of the collision.
8. On or about October 30, 2010, at approximately 8:36 a.m., Mr. Tillman was
front-seat passenger in the Tillmans' vehicle, which was being operated by his wife, Mrs
2
.m,-r _ _ _
Tillman, and was traveling northbound on State Route 11/15 (Camp Hill Bypass) approaching
the intersection with North 21st Street, Camp Hill, Cumberland County, Pennsylvania.
9. At approximately the same time and place, Defendant Bradley was operatin
Defendant's vehicle and was traveling southbound on State Route 11/15 (Camp Hill Bypass)
Camp Hill, Cumberland County, Pennsylvania.
10. At all times material hereto, the intersection of State Route 11/15 (Camp Hil
Bypass) and North 21st Street was controlled by a traffic light which was green for both traffi
traveling southbound and northbound on State Route 11/15.
11. Suddenly, and without warning, Defendant's vehicle entered the intersection o
State Route 11 / 15 and North 21st Street, and attempted to make a left turn onto North 21 s
Street, Camp Hill, Cumberland County, Pennsylvania.
12. Despite Mrs. Tillman's best efforts, she was unable to avoid a collision an
Defendant's vehicle violently collided with the front of Plaintiff s vehicle.
13. As a direct and proximate cause of Defendant Bradley's negligence, the Tillmans
vehicle was towed from the scene.
14. As a result of the aforementioned collision, Defendant Bradley was issued
citation pursuant to 75 Pa. C.S.A. § 3112 (Traffic Control Signals).
15. As a direct and proximate result of Defendant Bradley's negligence, Mr. Tillma
sustained damages as set forth more specifically below.
COUNTI
NEGLIGENCE
William Tillman v. Jill R. Bradlev
16. All prior paragraphs are incorporated herein as if set forth fully below.
3
i
17. The aforementioned collision and Mr. Tillman's resultant injuries are the direct'
and proximate result of Defendant Bradley's negligence generally and more specifically as set
forth below:
a. in operating Defendant's vehicle in careless disregard for the
safety of persons or property in violation of 75 Pa. C.S.A. § 3714;
b. in disregarding the speed of vehicles, the condition of the highway,
and the traffic upon the highway, in violation of 75 Pa. C.S.A. §
3361;
c. in failing to maintain proper and adequate observation of the
existing traffic conditions, in violation of 75 Pa. C.S.A. § 3309;
d. in failing to yield the right-of--way to vehicles lawfully traveling on
State Route 11/15 (Camp Hill Bypass);
e. in driving in a careless manner, in violation of 75 Pa. C.S.A. §
3714;
f. in disregarding a traffic control signal, in violation of 75 Pa. C.S.A.
§ 3112;
g. in failing to be reasonably vigilant to observe the Tillmans' vehicle
lawfully traveling upon the roadway;
h. in failing to be reasonably vigilant to observe the roadway and the
position of vehicles on State Route 11/15 (Camp Hill Bypass);
i. in failing to be continuously alert, in failing to perceive any
warning of danger that was reasonably likely to exist, and in failing
4
to have Defendant's vehicle under such control that injury to
persons or property could be avoided.
18. As a direct and proximate result of Defendant's negligence, Mr. Tillman has:
a. suffered personal injuries, including, but not limited to, broken
ribs and sternum, injuries to his left thumb, back pain, and injuries
to both of his elbows;
b. undergone continuing medical care for the aforesaid injuries;
c. suffered physical pain, discomfort, and mental anguish, and he will
continue to endure the same for an indefinite period of time in the
future, to his physical, emotional, and financial detriment and loss;
d. been compelled, in order to effect a cure for the aforesaid injuries,
to spend money for medicine and/or medical attention, and will be
required to spend money for the same purposes in the future, to his
detriment and loss;
e. suffered a loss of life's pleasures, and he will continue to suffer the
same in the future, to his detriment and loss;
f. been, and will in the future be, hindered from attending to his daily
duties and chores, to his detriment and loss.
19. Mr. Tillman believes and, therefore, avers that his injuries are permanent an
have caused permanent scarring.
WHEREFORE, Plaintiff, William Tillman, seeks damages from Defendant, Jill' R. Bradley
in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive o
interest and costs.
5
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COUNT II
LOSS OF CONSORTIUM
Deborah Tillman v. Jill R. Bradley
20. All prior pazagraphs aze incorporated herein as if set forth at length.
21. At all times material to this action, Mr. and Mrs. Tillman were lawfully married
as husband and wife.
22. As a result of Defendant Bradley's negligence, Mrs. Tillman has suffered a loss o
consortium, society, and comfort from her husband, Mr. Tillman, and she will continue to suffer
a similar loss in the future.
23. As a result of the negligence of Defendant Bradley, Mrs. Tillman has been
compelled, in order to effect a cure for her husband's injuries, to expend money for medicine and
medical attention and will be required to expend money for the same purposes in the future, to
her detriment and loss.
WHEREFORE, Plaintiff, Deborah Tillman, seeks damages from Defendant, Jill R.
Bradley, in an amount in excess of the compulsory arbitration limits of Cumberland County,
exclusive of interest and costs.
Respectfully submitted,
HANDLER, HENNING & ROSENBERG, LLP
Dated: Aug. 2012 By:
Andrew C. Speazs (PA 87737)
Attorneys for Plaintiffs,
William Tillman and Deborah Tillman
6
_ i
VERIFICATION
THE UNDERSIGNED hereby verify that the statements in the foregoing
document are based on information that was gathered by counsel in preparation of this
lawsuit. The language of the above-named document is of counsel and not our own. We
have read the said document and, to the extent that it is based on information that we gav
to counsel, it is true and correct to the best of our knowledge, information and belief. To
the extent that the contents of the said document is that of counsel, we have relied upon
our counsel in preparing this Verification.
THE UNDERSIGNED also understand that the statements therein are made
subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn
falsification to authorities.
DATE:
WILLIAM TILLMAN
D ORAH TILLMAN
Andrew C. Spears, Esquire
I.D.#87737
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000 Attorneys for Plaintiffs
Fax : (717) 233-3029
E-mail: Crosby@HHRLaw.com
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v. NO. 12-5403
JILL R. BRADLEY, CIVIL ACTION -LAW
Defendant
PLAINTIFF, WILLIAM TILLMAN'S REPLY TO
NEW MATTER AND NEW MATTER COUNTER CLAIM OF DEFENDANT
AND NOW, comes the Plaintiff, William Tillman, by and through his attorneys,
HANDLER, HENNING & ROSENBERG, LLP, by Andrew C. Spears, Esq., and replies
to the Defendant's' New Matter and New Matter Counter Claim as follows:
24. The averments of this paragraph constitute conclusions of law to which no
response is required. If a response is determined to be required, any and all allegations
and/or insinuations of wrongdoing on the part of Plaintiff are hereby denied. By way of
further response, the Pennsylvania Motor Vehicle Financial Responsibility Law speaks
for itself.
25. The averments of this paragraph constitute conclusions of law to which no
response is required. If a response is determined to be required, any and all allegations
and/or insinuations of wrongdoing on the part of Plaintiff are hereby denied. By way of
further response, the Pennsylvania Motor Vehicle Financial Responsibility Law speaks
for itself.
26. The averments of this paragraph constitute conclusions of law to which no
response is required. If a response is determined to be required, any and all allegations
and/or insinuations of wrongdoing on the part of Plaintiff are hereby denied By way of
further response, the Pennsylvania Motor Vehicle Financial Responsibility Law speaks
for itself.
27. The averments of this paragraph constitute conclusions of law to which no
response is required. If a response is determined to be required, any and all allegations
and/or insinuations of wrongdoing on the part of Plaintiff are hereby denied. By way of
further response, the Pennsylvania Motor Vehicle Financial Responsibility Law speaks
for itself.
NEW MATTER COUNTER CLAIM
28. The averments of this paragraph constitute an incorporation paragraph to
which no response is required. If a response is determined to be required any and all
allegations and/or insinuations of wrongdoing on the part of Plaintiff are hereby denied.
2'9 - 32. The averments of these paragraphs are not directed at Plaintiff,
William 'Tillman, so no response is required. If a response is determined to be required
any and all allegations and/or insinuations of wrongdoing on the part of Plaintiff, William
Tillman, are hereby denied.
2
WHEREFORE, Plaintiff,'JVilliam Tillman, respectfully requests that this
Honorable Court dismiss Defendant's New Matter and New Matter Counter Claim with
prejudice and enter such Order:> as are equitable and just.
Respectfully submitted,
DATED:~I ~~~` '~~~
Y
HANDLER, HENNING & ROSENBERG, LLP
a
BY~_ ~~ _
Andrev~^Spears, Esquire
I . D. #87737
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Attorney for Plaintiffs
1
J
VERIFICATION
PURSUANT TO PA R.C.P. NO. 1024 ~
Andrew C. Spears, Esquire, states that he is the attorney for the party filing the
foregoing document; that he makes this affidavit as an attorney, because the party he
represents lacks sufficient knowledge or information upon which to make a verification
and/or because he has greater personal knowledge of the information and belief than that
of the party for whom he makes this affidavit; and that he has sufficient knowledge or
information and belief, based upon his investigation of the matters averred or denied in the
foregoing document; and that this statement is made subject to the penalties of 18 Pa C.S.
§4904 relating to unsworn falsification to authorities.
Andrew C. ears, ~q iu re
Date: October 31, 2012
Andrew C:. Spears, Esquire
i. D.#87737
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000 Attorneys for Plaintiffs
Fax (717) 233-3029
F-mail• C:rnshvnHHRI aw rnm
WILLIAM TiLLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN CUMBERLAND COUNTY PENNSYLVANIA
Plaintiffs
v. NO. 12-5403
JILL R. BRADLEY, CIVIL ACT10N -LAW
Defendant
CERTIFICATE OF SERVICE
On the 30th day of October 2012, I hereby certify that a true and correct copy of
Plaintiff's Reply to New Matter and New Matter Counter Complaint of Defendant was served
upon the following by depositing in the U.S. Mail:
John Flounlacker, Esq.
Thomas, Thomas & Hafer, LLP
305 N Front St
P O Box 999
Harrisburg, PA 17108-0999
Respectfully submitted,
HANDLER, HENNING 8~ ROSENBERG, LLP
_~~
By:
Andrew .Spears, Esquire
I.D. #87737
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Law Offices of James L. Barlow
By: John P. Silli, Esquire
Attorney I.D. No.: 204907
900 E. 8th Avenue, Suite 301
King of Prussia PA 19406
(610)382-8100
WILLIAM TILLMAN
AND
DEBORAH TILLMAN, HIS WIFE
Plaintiff,
v.
JILL R. BRADLEY
V.
DEFENDANT
DEBORAH TILLMAN
Defendant.
Attorney for Additional Defendant,
Deborah Tillman
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
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NO. 12-5403
ENTRY OF APPEARANCE AND JURY DEMAND
TO THE PROTHONOTARY
Kindly enter my appearance on behalf of additional defendant, Deborah Tillman in the
above captioned matter. Defendant demands a trial by jury consisting of twelve (12) jurors.
LAW OFFICES OF JAMES L. BARLOW
JOHN P. SILLI, ESQUIRE
Attorney for Additional Defendant
Deborah Tillman
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Entry of
~-Vl
Appearance and Jury Demand was served via mail, this t~ day of November, 2012 upon
the following counsel of record:
Andrew C. Spears, Esquire
Handler Henning & Rosenberg LLP
1300 Linglestown Road
Suite 2
Harrisburg PA 17110
ATTORNEY FOR PLAINTIFF WILLIAM TILLMAN AND
DEBORAH TILLMAN, HIS WIFE
John Flounlacker, Esquire
Thomas Thomas & Hafer LLP
P.O. Box 999
305 N. Front Street
Harrisburg PA 17108-0999
ATTORNEY FOR DEFENDANT JILL R. BRADLEY
Dated: November ~~, 2012
~' n c~~
JOHN . SILLI, ESQUIRE
Law Offices of James L. Barlow
By: John P. Silli, Esquire
Attorney I.D. No.: 204907
900 E. 8th Avenue, Suite 301
King of Prussia PA 19406
(610) 382-8100
WILLIAM TILLMAN
AND
DEBORAH TILLMAN, HIS WIFE
Plaintiff,
v.
JILL R. BRADLEY
DEFENDANT
V.
DEBORAH TILLMAN
Defendant.
Attorney for Additional Defendant,
Deborah Tillman
COURT 4F COMMON PI~A~
CUMBERLAND COUN *~ ~.
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N0.12-5403
REPLY ON BEHALF OF ADDITIONAL DEFENDANT, DEBORAH TILLMAN TO
COUNTER-CLAIM OF CO-DEFENDANT JILL R. BRADLEY
28.-32. Denied. The allegations in the corresponding paragraphs of the New Matter
Counter-Claim are conclusions of law and they do not require any answer. Additional Defendant
denies that she was negligent or reckless or careless or that she caused the alleged injuries to any
degree. Additional Defendant is not liable to any party in this matter to any degree.
WHEREFORE, answering Additional Defendant, Deborah Tillman, demands judgment
in her favor and against Co-Defendant, Jill R. Bradley, together with costs, attorney's fees and
other such relief as this Court deems just and appropriate.
LAW OFFICES OF JAMES L. BARLOW
~~~~,
By: JOHN ~P. SILLI, ESQUIRE
Attorney for Additional Defendant
Deborah Tillman
VERIFICATION
I, John P. Silli, Esquire, hereby state that I am counsel for additional defendant, Deborah
Tillman in this matter and that all of the facts stated in the foregoing Reply to Counter-Claim are
true and correct to the best of my knowledge, information and belief. This Verification is taken
subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities.
i~~ ~c~
John . Silli, Esquire
Date: 11 I 1 ~ ~ 1 ~-
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Reply to
New Matter Counter-Claim was served via mail, this -ah day of November, 2012 upon
the following counsel of record:
Andrew C. Spears, Esquire
Handler Henning & Rosenberg LLP
1300 Linglestown Road
Suite 2
Harrisburg PA 17110
ATTORNEY FOR PLAINTIFF WILLIAM TILLMAN AND
DEBORAH TILLMAN, HIS WIFE
John Flounlacker, Esquire
Thomas Thomas & Hafer LLP
P.O. Box 999
305 N. Front Street
Harrisburg PA 17108-0999
ATTORNEY FOR DEFENDANT JILL R. BRADLEY
Dated: November (~ , 2012
JOHN P. SILLI, ESQUIRE
r�
Or THE PROTHONOTARY
2013 KAY -8 A1j 18: 11
THOMAS,THOMAS&HAFER LLPvUMBER L AND COUNT;' John Flounlacker,Esquire
305 NORTH FRONT STREET P E N N S Y VA N I A Attorney I.D.73112
P.O.BOX 999 717-237-7134
HARRISBURG,PA 17108 Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND COUNTY, PA
Plaintiffs,
NO. 12-5403-Civil
V.
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRIAL DEMANDED
Defendant,
V.
DEBORAH TILLMAN,
Defendant.
I
DEFENDANT JILL R. BRADLEY'S MOTION TO STRIKE DEFENDANT DEBORAH
TILLMAN'S OBJECTIONS TO DEFENDANT JILL R. BRADLEY'S SUBPOENA
DIRECTED TO FARMERS INSURANCE GROUP
AND NOW comes Defendant Jill R. Bradley, by and through her counsel, Thomas,
Thomas & Hafer, LLP, and files this Motion to Strike the Objections of Defendant Deborah
Tillman to Defendant Jill R. Bradley's Subpoena Directed to Farmers Insurance Group, and in
support thereof respectfully states as follows:
1. This negligence action arises from a motor vehicle accident that occurred on
October 30, 2010.'
' Pursuant to the applicable standard of review,the recitation of facts contained in the instant Motion and Brief are
based upon the allegations contained in Plaintiffs' Complaint. Accordingly,Defendant Jill R. Bradley makes no
adoptions or admissions thereof.
2. At the time of the accident; Plaintiff Deborah Tillman was operating a vehicle in
which her husband, Plaintiff William Tillman,was a passenger. (Complaint, ¶8).
3. Plaintiffs allege that Defendant Bradley caused Plaintiffs' injuries by, inter alia,
failing to observe the traffic signals on Route 11/15 and failing to yield to Plaintiffs' right of way.
(Complaint,¶ 17(a)-(i)).
4. In response to Plaintiffs' allegations, Defendant Bradley asserted Counterclaims
against Plaintiff Deborah Tillman asserting that Plaintiffs' injuries were caused by Plaintiff
Deborah Tillman's negligent operation of her vehicle. (Defendant Bradley's Answer to Plaintiffs'
Complaint,New Matter Counterclaim,T¶29-32).
5. As a result of the Counterclaim against Plaintiff Deborah Tillman, Deborah Tillman
is involved in the instant action as both a plaintiff and defendant.
6. Upon information and belief, Plaintiff William Tillman received First-Party
Benefits in the form of payment of his medical expenses relating to the injuries allegedly sustained
in the subject auto accident from Farmer's Insurance Group (hereinafter "Farmers'.'), as evidenced
by the Farmer's Payment Log produced in discovery by Plaintiff Deborah Tillman's counsel. A
true and correct copy of the Farmer's First Party Payment Log is attached hereto as"Exhibit A."
7. Defendant Bradley seeks to obtain Farmers' First-Party file for Plaintiff William
Tillman as the first-party file is reasonably calculated to contain the following:
a. Applications for Benefits filed by Plaintiff William containing descriptions,
cause, injuries, or witnesses relating to the accident;
b. Recorded statements or statements under oath provided by Plaintiff William
Tillman describing the causes, injuries, or witnesses relating to the accident;
1279863-1 2
s
C. Information relating to the treating physicians used in calculating Plaintiff
William Tillman's damages and any causation defense that may relate
thereto in light of potentially pre-existing conditions; and
d. Any photographs, medical diagrams, or quantitative documents relating to
Plaintiff William Tillman's alleged injuries.
8. Accordingly, pursuant to Pa.R.C.P. 4009.21, Defendant Bradley served a Notice of
Intent to File Subpoenas upon all counsel on December 4, 2012. A true and correct copy Defendant
Bradley's Notice of Intent, included as part of the Certificate Prerequisite to said Subpoena,
attached hereto as"Exhibit B."
9. The Notices specifically indicated Defendant Bradley's intent to serve a subpoena
in the form proposed upon Farmers, and contained a proposed Subpoena to be served upon
Farmers.
10. The proposed subpoena requests the following information:
Within twenty (20) days after service of this subpoena, you are ordered by the
court to produce the following documents or things: a complete copy of'all
information pertaining to William Tillman (DOB: 09/12/1950;
Policy/Certificate No. 0002632017; Claim Unit: 1017176498-1-3; DOL:
10/30/2010) including but not limited to: claim forms, medical records, medical
reports, recorded statements, photographs, bills, memos, notes and
correspondence.
Id. (emphasis in original).
11. As discussed below, the subpoena only seeks Farmer's file relating to Plaintiff
William Tillman, and does not seek any information relating to Deborah Tillman.
12. Following the expiration of the twenty-day time period, no objections had been
filed and Defendant Bradley accordingly served a Certificate Prerequisite and Subpoena pursuant
to Pa.R.C.P. 4009.21 on Farmers on January 16, 2013. A true and correct copy of Defendant
1279863-1 3
Bradley's Certificate Prerequisite and Subpoena Directed to Farms is attached hereto as "Exhibit
B."
13. On January 30, 2013, over five weeks after the expiration of the twenty-day
objection period, Defendant Deborah Tillman objected to Defendant Bradley's proposed subpoena.
(See Defendant Deborah Tillman's Objections to Defendant Jill R. Bradley's Subpoena Directed to
Farmers Insurance Group (hereinafter"Defendant's Objections").
14. Plaintiff William Tillman has not objected to the proposed subpoena.
15. Defendant Deborah Tillman, however, asserts that the Defendant Bradley's
subpoena of Plaintiff William Tillman's first-party benefits file: (1) "attempts to obtain documents
that are protected by attorney-client privilege"; (2) "attempts to obtain documents that are protected
by attorney work product'; and(3) "is overly broad." Defendant's Objections,¶¶ 1-3.
16. Under Pennsylvania law, "discovery `is liberally allowed with respect to any matter,
not privileged, which is relevant to the cause being tried."' PECO Energy Co. v. Ins. Co. of N.
Am., 852 A.2d 1230, 1233 (Pa. Super. 2004) (internal citation omitted).
17. Pennsylvania Rule of Civil Procedure 4003.1(b) specifically provides that"[i]t is not
ground for objection that the information sought will be inadmissible at trial if the information
sought appears reasonably calculated to lead to the discovery of admissible evidence." (Emphasis
added).
18. It is therefore the objecting party's burden to establish the non-discoverability of
information or documents; the non-moving party bears no such burden. See e.g., Winck v. Daley
Mack Sales, Inc., 21 Pa. D.&C.3d 399, 403-04 (C.C.P. Somerset Co. 1980) (noting that the party
objecting to the discovery has the burden of proof to establish that said discovery is non-
discoverable, rather than the proponent having the burden to establish that it is discoverable and that
1279863-1 4
"s
when in doubt, discovery should be liberally permitted); Yadouga v. Cruciani, 66 Pa. D. & C.4th
164, 168 (C.C.P. Lackawanna Co. 2004); see also Bock v. Baker,44 Pa. D.&C.3d 60, 64 (C.C.P.
Armstrong Co. 1987).
19. Application of attorney-client privilege requires confidential communications
made in connection with providing legal services. Com. v. duPont, 730 A.2d 970 (Pa. Super.
1999),petition for allowance of appeal denied, 749 A.2d 466 (2000).
20. The work product doctrine, as embodied in Rule 4003.3 of the•Pennsylvania Rule
of Civil Procedure, Pa.R.C.P. No. 4003.3, protects from disclosure, inter alia, "mental
impressions, conclusions or opinions respecting the value or merit of a claim or defense or
respecting strategy or tactics." Pa.R.C.P. 4003.3.
21. Pennsylvania Rule of Civil Procedure 4003.3 expressly provides:
Subject to the provisions of Rules 4003.4 and 4003.5, a party may obtain
discovery of any matter discoverable under Rule 4003.1 even though prepared in
anticipation of litigation or trial by or for another party or by or for that other
party's representative, including his or her attorney, consultant, surety,
indemnitor, insurer or agent. The discovery shall not include disclosure of the
mental impressions of a party's attorney or his or her conclusions, opinions,
memoranda, notes or summaries, legal research or legal theories. With respect to
the representative of a party other than the party's attorney, discovery shall not
include disclosure of his or her mental impressions, conclusions or opinions
respecting the value or merit of a claim or defense or respecting strategy or
tactics.
Id.
22. Defendant Deborah Tillman's defense counsel lacks standing to object on
attorney-client privilege grounds for records relating to William Tillman because Defendant
Deborah Tillman's defense counsel is not the attorney for William Tillman.
23. As noted above, Defendant Bradley seeks the first-party benefits file for Plaintiff
William Tillman, not Deborah Tillman. Moreover, attorney-client privilege applies only to
1279863-1 5
confidential communications involving the client and lawyer, and accordingly bears no
application to first-party insurance carriers' files.
24. As noted above, Plaintiff William Tillman has not objected to the proposed
subpoena.
25. As a result, Defendant Deborah Tillman's objection on the grounds of attorney-
client privilege are wholly inapplicable to claims for privilege relating to Plaintiff William
Tillman.
26. Next, Defendant Deborah Tillman's objections are temporally flawed, even
assuming the applicability of any privilege or attorney work product.
27. Indeed, even assuming Defendant Deborah Tillman somehow had standing to
make the objections, any communications between Defendant Deborah Tillman and her defense
counsel would have to had occurred after Defendant Deborah Tillman received notice of the
Counterclaim's against her, thereby triggering the need for separate defense counsel.
28. Defendant Deborah Tillman was not a defendant in this action, and therefore did
not have defense counsel until after Defendant Bradley filed Counterclaims against Defendant
Tillman on or about October 9, 2012.
29. Even assuming that some portion of Farmer's first-party claims file for Plaintiff
William Tillman contained information protected by attorney-client privilege or the work
product doctrine, the file is still discoverable as counsel may redact whatever portions are
privileged or protected.
30. Further, the untimeliness Defendant Deborah Tillman's objections, having been
made approximately five weeks after the expiration of the twenty-day period, weighs in favor of
overruling said objections.
1279863-1 6
31. Lastly, there are exceptions to the general rule of inadmissibility set forth in Pa.R.E.
404(b). See Pa.R.E. 404(b)(2). If Counsel for Plaintiff believes that the subpoenaed records are
l
inadmissible at trial based on Pa.R.E. 404(b), or for any reason, then said counsel certainly can file
the appropriate motion in limine to preclude the introduction of said evidence. Defendant Bradley
should not be precluded from simply discovering said documents, however, since they may contain
relevant information.
WHEREFORE, Defendant Jill R. Bradley respectfully requests this Honorable Court grant
Defendant Bradley's Motion to Strike Plaintiff's Objections to Defendant Bradley's Subpoena to
Farmers Insurance Group, thereby allowing Defendant Bradley to issue said Subpoena in
accordance with Pa.R.C.P. 4009.21.
Respectfully submitted,
THOM , THOM AFER, LLP
By-
er, re
A e 112
orey J. A son, Esquire
Attorn D. #204508
P . ox 999
305 N. Front Street
Harrisburg, PA 17108-0999
(717)237-7134
Date: 1p
1279863-1 7
15• ��
Payment , , FARM E R5'
Unit Number: 1017176498-1-5
t
Date of Loss: 1013012010
Claimant's Name WILLIAM TILLMAN
Insured's Name: WILLIAM TILLMAN
Benefit Type: Medical
Cheek Number Service From Service To Payee. Gate Issued Date Pald Paid Amount Check Amount
Date Date
1270586450 12/1412010 12114/2010 NIEDSTAR HEALTH ANES SERV A LL 04/21/2011 04/2712011 $140.94 $140.94
1270586449 03/23/2011 03/23/2011 BRAYER PHYSICAL THERAPY 0412112011 0412712011 $98.25 $98.25
INSTIT
1270584715 03/1612011 0311912011 BRAYER PHYSICAL THERAPY 04/13/2011 0412112011 $300.15 $300.15
1274584714 0312112011 0312112011 BRAYER PHYSIAL THERAPY 04/13/2011 0412112011 $133.01 $133.01
1270584716 02124/2011 0212412011 ORTHOPADIC AN D SPINE SPECIAL 0411312011 04122/2011 $167.52 $167.52
1270578413 02118/2011 02118/2011 WELLSPAN MEDICAL GROUP 0312312011 03131/2011 $81.27 $8127
1270378412 0212412011 0212412011 ORTHOPAEDIC AND SPINE SPECIAL 0312312011 0313112011 $71.40 $71.40
1270578414 02/18/2011 02/18/2011 YORK HOSPITAL 03123/2011 0313112011 $769.80 $769.80 �yaati+
1270574565 0212412011 0212412011 CYPRESS CARE INC 03/1012011 03117/2011 $24.97 $24.97
1270574556 02/18/2014 0211812011 WELLSPAN MEDICAL GROUP 03110/2011 0311812011 $87.55 $87.55
1270571909 12114/2010 LUTHERVILLESURGICENTER 0310111011 03109!7011 $1055.00 $1055.00
1270564362 1211412Q10 GREATER CHESAPEAKE HAND 0112712011 0211612011 $1210.00 $1210.00
SPECIALISTS P
1270564366 01/0512011 0110512011 WELLSPAN MEDICAL GROUP 01/27/2011 0210312011 $117.24 $117.24
1270559763 1210712010 12/07/2010 WELLSPAN MEDICAL GROUP 01111.12011 0112112011 $168.45 $168.45
1270557890 12/14/2010 1211412010 CYPRESS CARE INC 01103/2011 01111/2011 $14.57 $14.57
1270556289 11/2912010 1112912010 GRATER CHESAPEAKE HAND 1?,12212010 01/05/2011 $110.00 $110.00
SPECIA
12TO551976 1,110812010 11108/2010 WELLSPAN MEDICAL GRPOP 12106/2010 12/17/2010 $70.06 $70.06
Page 1 of 2
FA R M E RS Report Generated for USIJVKYC16 on 10/1012011
4Y
Payment • • 1 SwwiN
1270551939 11101/2010 1110112010 WELLSPAN MEDICAL GROUP 12106/2010 12117/2010 $18.52 $18.52
1270551407 11/01/2010 11101!2010 WELLSPAN MED[GALGROUP 1210212010 1211012010 $29.84 $29.84
1270550007 11101/2010 1110112010 YORKHOSPITAL 1112412010 1210312010 $223.02 $223.02
1270550005 11/0112010 11/0112010 WELLSPAN MEDICAL GROUP 11124/2010 12103/2010 $108.44 $108.44
Benefit Type Total : $5000.00 $5000.00
Total Amount: $5000.00 $5000.00
Comments:
i
t 'j FARMERS Report Generated for USWICfC16 on 1 011 0120 1 1 Page 2 of 2
QFFICE
THOMAS,THOMAS&HAFER,LLP N}
z0J Fdfl TA
John Flounlacker,Esquire 3 JA�j 17
Attorney ID#73112 AM
PO Box 999 1�,ER-t A�
Harrisburg,PA 17108-0999 P f Js Y D COUNTY
717-237-7134 LVANIA Attorneys for Defendant
E-mail:Founlacker@tthlaw.com
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN,his wife, CUMBERLAND CO., PENNSYLVANIA
Plaintiffs
V. NO. 12-5403 .
JILL R. BRADLEY, CIVIL ACTION— LAW
Defendant
JURY TRIAL DEMANDED
AC;ERTIFI�CAtTE::�P REQU S1#E`TO&SS�JA�TCE�OF ��I7B1P�:EN' � t
TO�'RO.DZJ<CEDOCLT1VfE' S ATDxTH�NGSO.R
Ya Y
r�� ,`'?�.�`"" h "L `•`.1'l.YSC3�.�U;ERI'�PaUtRSLT13�TI'.TO�R�`E ' oo. 2Y ' ..�. �x� ;.
4 9• �-
As a prerequisite to service of subpoenas for documents and things pursuant to
Rule 4009.22,Defendant certifies that:
1. A Notice of Intent to Serve Subpoenas, with copies of the subpoenas
attached thereto,was mailed or delivered to each party;
2. A copy of the Notice of Intent, including -the proposed subpoenas, is
attached to this Certificate;
3. Twenty(20) days have passed and no objections have been filed; and
4. The subpoenas which will be served are identical to the subpoenas Which
are attached to the Notice of Intent to Serve Subpoenas.
THOMAS, THOMAS & HAFER, LLP
By
John Flounlacker, Esquire
Attorneys for Defendant
Date: January 16, 2013
EXHIBIT
THOMAS,THOMAS&HAFE,R LLP John Flounlacher,Esquire
305 NORTH FRONT STREET Attorney J.D. 73112
P.O.BOX 999 71'7-237-7134
HARRISBURG,PA 17108 Corey J. Adamson,Esquire
Attorney I.D.2045008
Att omeys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN,his wife, CUMBERLAND COUNTY, PA
Plaintiff(s)
NO. 12-5403-Civil
V.
Cn7IL ACTION—LAW
JILL R. BRADLEY, I JURY TRIAL DEMANDED
Defendants)
YOTICEO-FXqTENTTTO'SEt-RN.'T SUBPOENAS
'T,
'TO ODUIGBiDO G,�.TN :a?;=3--
Gs
'SU-A A'TT'ITZO MU
E4009'21"
TO: Counsel of Record
Defendant intends to 'Serve the 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 objections to these subpoenas. If no objections are made, the subpoenas will
be served.
THOMAS, THOMAS &HAIFE(R, LLP
Date: December 4,2012
JOHN FLOUNLACIGR
Attomey for Defendant
1203429A
THOMAS,THOMAS&,HAFERLLP John Flouniacker,Esquire
305 NORTH FRONT STREET Attorney J.D.73112
P.O.BOX 999 717-237-7134
HARRISBURG,PA 17108 Core),J.Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND COUNTY,PA
Plaintiff(s)
NO, 12-5403-Civil
V.
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRIAL DEMANDED
Defenda-nt(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Chanceford Family=Medicine. 10 Muddi,Creek Forks Road. Suite 3.Brogue.FA 17309
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a complete copy of all medical records pertaining to William Tillman
(DOB: 09/12/19501 including but not limited to: emergency department records. evaluations. consultation
re,Dorts. nursing notes. thera pv notes. proc gress notes. discharge summaries. records of other health care
providers. Datient histories.TeDorts of diagnostic studies. correspondence and medical bills from 2000 to
the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party malting this request at the address listed above.
V
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days
after its service,the part),serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENAVVAS ISSUED AT THE REQUEST OF TFIE FOLLOWING PERSON:
NAME: Jolui FlounlaGlcer,Esquire
ADDRESS: P.O.Box 999,I'lamisburg,PA 17108-0999
TELEPBONE: (717)237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendants
BY TBE COURT:
DATE:
Sea] of the Court Prothonotary/Clerk, Civil Division
Deputy
THOMAS,THOMAS& HAFEIRLLP John Flounlacker,Esquire
305'NORTF3 FRONT STREET Attorney I.D. 73112
P.O.BOX 999 717-237-7134
HARRISBURG,PA J7108 Corey I Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIA1v4 TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND COUNTY, PA
Plaintiff(s)
NO. 12-5403-Civil
V.
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRLA-L DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCO17BRY PURSUAYT TO RULE 4009.22
TO: Orthopaedic and Spine Specialists. 1855 Powder Mill Road,York.PA 17402
Within twenty (20) days after service of this subpoena, you are ordered by the court to -produce the
following documents or things: a complete con, of all medical records pertaining to William Tillman
(DOB• 09/12/1950) including but not limited to: emergency department records. evaluations. consultation
reports nursing notes therapy notes. progress notes, discharge summaries. records of other health care
providers patient histories:reports of diagnostic studies, correspondence and medical bills from 2000 to
the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party making this -request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days
after its senice,the party sening this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT TFIE REQUEST OF THE FOLLOWING PERSON:
NAME:John Flour tacker,Esquire
ADDRESS:P.O. Box 999,Harrisburg,PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT IDIt: 73 112
ATTORNEY FOR: Defendants
BY THE COURT:
DATE:
Sea] of the Court Prothonotary/Clerk, Civil Division
Deputy
John Flounlacker,Esquire
THOMAS,THOMAS&HAFER LLP Attorney I.D.73112
305 NORTH FRONT STREET 717-237-7134
P.O.BOX 999 Corey J. Adamson,Esquire
HARRISBURG,PA 1710E Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN,his wife, CUMBERLAND COUNTY, PA
Plaintiff(s)
N0, 12-5403-Civil
V.
CIVIL ACTION—LAW
JILL R, BRADLEY, JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINC<S
FOR DISCOVERY PT SUANT TO RULE 4009.22
TO: OSS Ambulatory Surgery Center. 1855 Powder Mill Road.York.PA 17402
VA7ithin twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a com lete co v of all medical records pertaining to William Tillman
OB: 09/12/1950 including but not limited to: emergenev department records. evaluations. consultation
re orts. nursing notes. thera notes progress notes. discharge summaries. records of other health care
providers.pad nt histories,reports of diagnostic studies. correspondence and medical biIls from 2000 to
the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, .
together with the certificate of compliance, to the party malting this request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena,within twenty (20) days .
after its service,the party serving this subpoena may seek a court order compelling you to coinply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker,Esquire
ADDRESS: P.O.Boa 999,Harrisburg,PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT H& 73112
ATTORNEY FOR:Defendants
BY THE COURT:
DATE:
Seal of the Court Prothonotary/Clerk, Civil Division
Deputy
THOMAS,THOMAS&RAFE R LLF John Flounlacker,Esquire
305 NORTH FRONT STREET Attorney I.D. 73112
P,O,BOX 999 717-237-7134
HARRISBURG,PA 17108 Corey J. Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his.wife, CUMBERLAND COUNTY, PA
Plaintiff(s)
NO. 12-5403-Civil
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Draver PT,781 Far Hills Drive, Suite 400, Nem,Freedom.PA 17349
Within twenty (20) days after service 'of this subpoena, you are ordered by the court to produce the
following documents or things: a complete co-riv of all medical and therapi, treatment records
r)ertaininL, to NN'illiam Tillman (DOB: 09/12/1950) including but not limited to: emergency department
records. evaluations, consultation reports, nursing notes. therapy notes. Progress notes. discharge
summaries. records of other health care providers. patient histories. reports of diagnostic studies.
correspondence and medical bills from 2000 to the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the part), making this request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena,within twenty (20) days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: Jolin Flounlacker,Esquire
ADDRESS:P.O.Box 999,Harrisburg,,PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT ID#; 73112
ATTORNEY FOR: Defendants
BY THE COURT:
DATE:
Sea] of the Court Prothonotary/Clerk, Civil Division
Deputy
THOMAS,THOMAS&HAFER LLP John Flounlacker,Esquire
305 NORTH FRONT STREET Attorney I.D. 73112
P.O,BOX 999 717-237-7134
BAMSBURG,PA 17108 Core),I Adamson,Esquire
Attorney LD,2045008
Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND COUNTY, PA
Plaintiff(S)
NO. 12-5403-Civil
V,
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Neurodia2noitic Associates of Maryland,PC. 4C North Avenue. Suite 425. Bel Air.MI) 21014
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a complete cop, of all medical treatment records pertaining to 'William
Tillman (DOE: 09/1211950) including but not limited to: emergency department records. evaluations.
consultation rMorts nursing notes therapy notes, progress notes. discharge summaries. records of other,
health care providers patient histories reports of diagnostic studies. correspondence and medical bills
from 2000 to the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the part), malting this request at the address listed above.
You have the right to seelc in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena,within twenty (20) days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it,
THIS SUBPOENA-WAS ISSUED AT THE REQUEST OF TIM FOLLO)�7ING PERSON:
NAME: John Flounlacker,Esquire
ADDRESS:P.O.Box 999,Harrisburg,PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendants
BY THE COURT:
DATE:
Sea] of the Cowl Prothonotary/Clerk, Civil Di-vision
Deputy
T11 OMAS,THOMAS&EAFE R LLP John Flounlacker,Esquire
305 NORTH FRONT STREET Attorney I.D. 73112
P,0.BOX 999 717-237-7134
HARRISBURG,PA 17108 Core),I Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND COUNTY, PA
Plaintiff(s)
NO. 12-5403-Civil
V.
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR TEFINGS
FOR DISCOITRY PURSUANT TO RULE 4009.22
TO: Greater Chesapeake Hand Specialists. 1400 Front Ave.. Suite 100. Luthervifle, MD 21093
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a complete con, of all medical treatment records pertaining to William
Tillman (DOB: 09/12/1956 including but not limited to: emergency department records. evaluations,
consultation reports nursing notes therapy notes. proo—Tess notes. discharge summaries. records of other
health care providers patient histories,-reports of diagnostic.studies, correspondence and medical bills
from 2000 to the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party malting this request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the thing's
sought. If you fail to produce the documents or things required by this subpoena,within twenty (20) days
after its service,the part),serving this subpoena may seek a court order compelling you to comply with it,
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker,Esquire
ADDRESS: P.O, Box 999,Harrisburg,PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR:Defendants
BY THE COURT:
DATE:
Sea] of the Court Prothonotary/Clerk, Civil Division
Deputy
THOMAS,THOMAS&HAFER LLP John Flounlacker,Esquire
305 NORTH FRONT STREET Attomey LD.73112
P.O.BOY 999 717-237-7134
HARRISBURG,PA 17109 Corey I Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN,his wife, CUMBERLAND COUNTY, PA
Plaintiff(S)
NO. 12-5403-Civil
V.
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRIAL DEMANDED
Defendant(S)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Farmers Insurance Groun. PO Box 268994, Oklahoma Cite. OK 73126-8994
'Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a com lete 030v of all information -Dertainina to William Tillman
(DOB: 09/12/1950: Policy/Certificate No. 0002632017: Claim Unit: 1017176498-1-3: DOL:
10/30/2010) including but not limited to: claim forms medical records. medical reuorts. recorded
statements. hotoc-T hs. bills.memos. notes and correspondence.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party making this request at the address listed above.
You have the right to seek in advance,the reasonable cost of preparing the copies of producing the things
sought. If you fail to produce the documents or things required by this subpoena,within twenty (20) days
after its service,the party sensing this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA VdAS ISSUED AT THE REQUEST OF THE FOLLO-WING PERSON:
NAME: John Flounlacker,Esquire
ADDRESS: P.O.Box 999,Harrisburg,PA 17108-0999
TELEPHONE: (717)237-7134
SUPRE14E COURT 1D#: 73112
ATTORNEY FOR:Defendants
BY THE COURT:
DATE:
Seal of the Court Prothonotary/Clerk, Civil Division
Deputy
CERTIFICATE OFSERIICE
AND NOS',this 40'day of December 2012, 1, DEENA B. MORRISON, a Paralegal in the
lam, firm of Thomas, Thomas & Hafer, LLP,hereby certify that I sent a true and correct copy of the
foregoing document by placing a cop), of the same in the United States Mail, first class, postage
prepaid, to the following:
Andrew C. Spears,Esq.
Handier, Henning &Rosenberg, LLP
1300 Linglestown Road, Suite 2
Harrisburg,Pa 17110
John P. Silli, Esq.
Law Offices of James L. Barlow
900 E. 8th Avenue, Suite 301
King of Prussia,Pa 19406
Deena B. Morrison, legal
1203429.1
CERTIFICATE OF SERVICE
I, Deena B. Morrison, a Paralegal for the law firm Thomas, Thomas & Hafer, LLP,
hereby state that a true and correct copy of the attached Certificate Prerequisite was
served upon all counsel of record by first class United States mail, postage prepaid,
addressed as follows, on the date set forth below:
Andrew Spears, Esquire John P. Silli, Esquire
Handler, Henning&Rosenberg, LLP Lave Offices of James L. Barlow
130o Linglestown Road, Suite 2 goo East 8th Avenue, Suite 301
Harrisburg, PA 17110 King of Prussia, PA 17406
THOMAS,THOMAS &HAFER, LLP
Deena B. Morrison, Paralegal
Date: January 16, 2012
1223549.1
CERTIFICATE OF SERVICE
a legal secretary for the law firm Thomas, Thomas &
Hafer, LLP, hereby state that a true and correct copy of the attached document(s) was served upon
the following persons as indicated on the date set forth below:
Andrew C. Spears, Esquire
Handler, Henning & Rosenberg, LLP
1300 Linglestown Road, Suite 2
Harrisburg, Pa 17110
John P. Silli, Esquire
Law Office of James L. Barlow
900 East 8th Avenue, Suite 301
King of Prussia, PA-19406
Dated: G yl 13
I
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND COUNTY, PA
Plaintiffs,
NO. 12-5403-Civil
V. ;
CIVIL ACTION—LAW
JILL R. BRADLEY, JURY TRIAL DEMANDED
Defendant,
V.
DEBORAH TILLMAN,
Defendant.
ORDER
AND NOW, this/3 day of .4m , , 2013, upon consideration of
Defendant Jill R. Bradley's Motion to Strike Defendant Deborah Tillman's Objections to
Defendant-Bradley's Subpoena to Farmers Insurance Group, Defendant Bradley's Motion is
hereby GRANTED. Defendant Deborah Tillman's Objections to Defendant Bradley's Subpoena
to Farmers Insurance Group are hereby STRICKEN, and Defendant Bradley is hereby
PERMITTED to serve its Subpoena upon Farmers Insurance
J.
7.1
nj
�rY]
CERTIFICATE
PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22
IN RE:
William Tillman and Deborah Tillman, CumberlandCounty
his wife
vs. No.: 12-5403
Jill R. Bradley, et al.
As a prerequisite to service of a subpoena for documents and things pursuant to
Rule 4009.22
Digital Legal, on behalf of John P. Silli, Esquire certifies that:
1. A Notice of Intent to Serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to each party at least twenty
(20)'days prior to the date on which the subpoena is sought to be
served;
2. A copy of the Notice of Intent, including the proposed subpoena, is
attached to this certificate;
3. No objections to the subpoena has been received and/or the twenty
(20) day period has been waived; 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.
Digital Legal, on behalf of
John P. Silli, Esquire
Attorney for Defendant ,
Date: July 17, 2013 ,
z nl C=
12582 �r `�"" ter-•
.c >.
w
Digital Legal
1800 JFK Boulevard
Suite 604
Philadelphia, PA 19103
Phone 215.569.9155
Fax 215,569,0690
May 23, 2013
RE: Tillman v. Jill R. Bradley, et al.
To: Andrew Spears, Esquire, 1300 Linglestown Road, Harrisburg, PA
John Flounlacker, Esquire, 305 K Front Street, Harrisburg, PA
Enclosed is the Notice of Intent to Serve a Subpoena to Produce Documents and
Things for Discovery Pursuant to Rule 4009.21 and accompanying subpoenas with
reference to the above matter.
Also enclosed is a Request Form which we request that you complete and fax to
- 215.569.0690 if you wish to be provided with copies of the requested records at your
expense .
Should you have any questions concerning the enclosed materials, please contact me at
215.569.9155. Thank you.
Very truly yours,
DIGITAL LEGAL
Stephanie Rucier
12582
Commonwealth of Pennsylvania
County of Cumberland
William Tillman and Deborah Tillman, his wife
No. 12-5403
Plaintiff
V.
Jill R. Bradley, et al.
Defendant
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO.RULE 4009.21
3) York Hospital(Medical Records)
4).Carl Brango, M.D. (Medical Records)
5) York Hospital(Radiology Records)
To: Andrew Spears, Esquire, 1300 Linglestown Road, Harrisburg, PA
John Flounlacker, Esquire, 305 N. Front Street, Harrisburg, PA
Digital Legal on behalf of John P. Silli, Esquire intends to serve a subpoena(s)identical
to the one(s) attached to this notice. You have twenty(20)days from the date listed
below in which to file of record and serve upon the undersigned an objection to the
subpoena. If no objection is made or if the twenty(20)day notice is waived the
subpoena(s) may be served.
Any inquiries regarding this matter may be directed to Stephanie Rucier at Digital Legal
215.569.9155.
Date: May 23, 2013
.12582
Digital Legal
9800 JFK Boulevard
Suite 604
Philadelphia, PA 99903
Phone 295.569.9955
Fax 295.569.0690
Date: May 23, 2013
To: Andrew Spears, Esquire, 1300 Linglestown Road, Harrisburg, PA
John Flounlacker, Esquire, 305 N. Front Street,,Harrisburg, PA
RE: Tillman v. Jill R. Bradley, et al.
We.have received request for records from John P. Silli, Esquire, from the following
providers:
3) York Hospital(Medical Records)
4) Carl Brango, M.D. (Medical Records)
5) York Hospital(Radiology Records)
Kindly advise if you are willing to waive the twenty-day notice period as required by
the Pennsylvania Rules of Civil Procedure by signing and returning this document by
facsimile to 215.569.0690 attention Barbara Ganley.
I AGREE to waive the 20-day notice
I would like to obtain copies of any and all records.
BY SIGNATURE BELOW, AND RETURN OF THIS FAX REQUEST, THE
UNDERSIGNED AGREES TO PAY FOR THE COSTS IN OBTAINING COPIES IN
CONNECTION WITH THE REQUEST
I OBJECT to the waiver of the 20-day notice
Attorney Signature Attorney name(printed)
Date
ELECTRONIC DELIVERY
(pdf format) EMAIL ADDRESS FOR DELIVERY OR
PDF images on CD:
12582
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
William Tillman and Deborah Tillman,hlw ,
File No. 12-5403
V. `
Jill R.Bradley,et al. `
SUBPOENA TO PRODUCE DOCUMENTS OR THONGS
FOR DISCOVERY PURSUANT TO RULE 4009,22
TO: Custodian of Records of: York Hospital-Medical Records Department
(Name of Person or Entity)
Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the
following documents or things:
*** SEE ATTACHED ADDENDUM ***
at Digital Legal, 1800 JFK Boulevard, Suite 604,Philadelphia,PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena,together with the certificate of compliance,to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought
If you fail to produce the documents or things required by this subpoena within twenty(20)days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John P. Silli,Esquire
ADDRESS:900 East 8th Avenue
Suite 301
King of Prussia.PA 19406
TELEPHONE: 215-569-9155 tephanie Ru_cier
SUPREME COURT ID# 204907
ATTORNEY FOR —Defendant
BY THE COURT:
Prothonotary,Civil Division
Date:
'Seal ofthe Court Deputy
ADDENDUM TO SUBPOENA
William Tillman and Deborah Tillman, his wife Cumberland County
No. 12-5403
V.
Plaintiff
Jill R. Bradley, et al.
Defendant
CUSTODIAN OF RECORDS OF: York Hospital
Medical Records Department
Any and all records, including but not limited to, medical records, electronic
records, correspondence to and from the consulting and treating physicians,
office notes, treatment records, memoranda, histories, reports, files, index cards,
charts, graphs, discharge summaries, and any other information pertaining to the
treatment of:
Name: William Tillman
DOB: 09/1211950
SSN: 215-50-0399
12582.003
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
William Tillman and Deborah Tillman,h/w 12-5403
File No.
V. ,
Jill R.Bradley,et al. ,
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records of Carl Brango,M.D.
(Name of Person or Entity)
Within twenty(20)days after service of this subpoena,you are ordered by the coact to produce the
following documents or things:
*** SEE ATTACHED ADDENDUM ***
at Digital Legal, 1800 JFK Boulevard, Suite 604,Philadelphia,PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena,together with the certificate of compliance,to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the.
things sought.
If you fad to produce the documents or things required by this subpoena within twenty(20)days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John P. Silli,Esquire
ADDRESS:900 East 8th Avenue
Suite 301
Kine of Prussia.PA 19406
TELEPHONE: 215-569-9155 Stephanie Rucier
SUPREME COURT ID# 204907
ATTORNEY FOR: De en ant
BY THE COURT:
Prothonotary,Civil Division
Date:
'Seal of the Court Deputy
ADDENDUM TO SUBPOENA
.William Tillman and Deborah Tillman, his-wife Cumberland County
12-5403
V.
Plaintiff
Jill R. Bradley, et al.
Defendant -
CUSTODIAN OF RECORDS OF: Carl Brango, M.D.
Any and all records, including but not limited to, medical records, electronic
records, correspondence to and from the consulting and treating physicians,
office notes, treatment records, memoranda, histories, reports, files, index cards,
charts, graphs, discharge summaries, and any other information pertaining to the
treatment of:
Name: William Tillman
DOB: 09/12/1950
SSN: 2-15-50-0399
12582.004 _
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
William Tillman and Deborah Tillman,h/w 1
File No. 2-5403
V. ,
Jill R.Bradley,et al. ,
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records of. York Hospital-Radiology Records Department
(Name of Person or Entity)
Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the
following documents or things:
* * SEE ATTACHED ADDENDUM ***
at Digital Legal, 1800 JFK Boulevard,Suite 604,Philadelphia.,PA 19103
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena,together with the certificate of compliance,to the party making this request at the address listed
above. You have the right.to seek in advance the reasonable cost of preparing the copies or producing the
bungs sought
If you fail to produce the documents or things required by this subpoena within twenty(20)days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John P. Silli,Esquire
ADDRESS:900 East 8th Avenue
Suite 301
Kine of Prussia.PA 19406 .
TELEPHONE: 215-569-9155 Stephanie Rucier
SUPREME COURT M# 204907
ATTORNEY FOR: Defendant
BY THE COURT:
Prothonotary,Civil Division
Date:
'Seal of the Court Deputy
ADDENDUM TO SUBPOENA
William Tillman and Deborah Tillman, his wife Cumberland County
12-5403
Plaintiff
V.
Jill R. Bradley, et al.
Defendant
CUSTODIAN OF RECORDS OF: York Hospital
Radiology Records Department
Any and all radiology films*and reports, including but not limited to, radiology
reports and films, and any other information pertaining to the treatment of:
Name: William Tillman
Date of Birth: 09/12/1950
SS N: 215-50-0399
*Please provide an inventory of films before,copying and sending
12582.005
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTt'
�"'`�� -nom � ��'-`•
TILLMAN, ET AL _
C:D
Vs .
NO. 125403 <� °
TILLMAN t. Z C3"n
CERTIFICATE '
PREREQUISI'T'E TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4049.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 JOHN SILLI, ESQUIRE certifies that:
1 . A Notice of Intent to Serve the Subpoena(s) with ,a copy of
the subpoena,(s) attached thereto was mailed or delivered 'to
each party at least twenty days prior to the date' on which
the subpoena(s) is sought to be served,
2: A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3 . No objection to the subpoena(s) has been received, and
4 . The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s) .
Date: 09/04/13 JOHN SILLI, ESQUIRE
900 E 8TH AVE
SUITE 301
KING OF PRUSSIA, PA 19406
..610-382-8100
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO;
k MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(866) 470-0535
By: Michele Lawson
MLR File ##: L414004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
TILLMAN, ET AL '
Vs.
TILLMAN No. 125403
TO: ANDREW SPEARS, ESQ (PLAINTIFF)
JOHN FLOUNLACKER
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the ones) attached to this notice. You have twenty (20) days
from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is
made the subpoena may be served.
Date: 08/13/13 JOHN SILLI, ESQUIRE
900 E 8TH AVE
SUITE 301
KING OF PRUSSIA, PA 19406
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(866) 470-0535
By: Michele Lawson
Enc (s) : Copy of subpoena(s)
Counsel return card
File #: L414004
rrmAnmWEALTH OF pERNSYLVANIA
Cowry OF cumBERLAND
TILLMAN, ET AL
Vs. File No. 125403
TILLMAN
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISOOVERY PURSUANT TO RULE 4009.22
YORK HOSP, 1001 S GEORGE ST, YORK PA 17405-7198
TO: ATTN• BETH-GEESEY/REL OF INFO
.(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the fo I I ow i ng documents or t 9s.
sp r
at
MEDICAL LEGAL REPRODUCTION%cip
rges 4940 DISSTON ST. , PHILA.., PA
You may deliver or mail legible copies of the docu-nents or produce things requested ►,�
this subpoena, together with the certificate of carp I i ance, to the party making th i Z
request at the address listed above. You have the right to seek in advance the reasonable
cost of preparing the copies or producing the things sought.
if you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving ' this subpoena may seek a court ordei-
ampelling you to cat ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: JOHN SILLI, ESQ
ADDRESS: qnn R ATM AVR
KING OF PI�USSIA, PA 19406
TELEPHONE:
SUPREME COURT -10 # 215-335-3212
ATTORNEY FOR:
DEFENDANT
BY THIr
L414004-01
DATE:
Seal of thd
Deputy
(Eff 7/97)
ADDENDUM TO SUBPOENA
TILLMAN, ET AL
Vs.
No. 125403
TILLMAN
CUSTODIAN OF RECORDS FOR: YORK HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray reports, out-patient records physical
therapy records, and any other information pertaining to:
NAME: WILLIAM TILLMAN
ADDRESS:
DATE OF BIRTH: 09/12/50
SSAN: 215500399
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
I RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE.- I hereby certify that a thorough search
has been made and that no record of .the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS PATIENT BILLING
X-RAYS RECORDS / XRAYS have been destroyed
Date Authorized signature for
YORK HOSP
CUMBERLAND
L414004-01
SIGN AND RETURN THIS PAGE
COMVIDNWEALTH OF PENNSYLVANIA
00UNrY OF CUblBERLAND
TILLMAN, ET AL
Vs. File No. 125403
TILLMAN
ORIGINAL X-RAYS REQUESTED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISOOVERY PURSUANT TO RULE 4009.22
YORK HOSP, 1001 S GEORGE ST, YORK PA 17405-7198
TO: ATTN: BETH GEESEY/REL OF INFO -
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
S.
produce the following docu SEments or thinE g *A —
TTACHED ADID NVUM
at
MEDICAL LEGAL REPRODUCTIONS(,AdT#ges)4940 DISSTON ST. , PHILA. , PA
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of caMliance, to the party making thiZ
request at the address listed above. You have the right to seek in advance the rea7,onable
cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving thir, subpoena may seek a court ordet-
cxmpelling you to caTply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: JOHN SILLI, ESQ
ADDRESS: 9 n n F. RTLL AV
ICING OF Pl�dSSIA, PA 19406
TELEPHONE:
SUPREME' 00URT I D 215-335-3212
ATTORNEY FOR:
DEFENDANT
BY THE COURT:
L414004-02
Q Proth lerlf-%, civil avislon
DATE: )13 -
Seal of the Court
DeputY
(Eff. 7/9T)
ADDENDUM TO SUBPOENA
TILLMAN, ET AL
Vs .
TILLMAN No. 125403
CUSTODIAN OF RECORDS FOR: YORK HOSP
ANY AND ALL FILMS .
PERTAINING TO: '
NAME: WILLIAM TILLMAN
ADDRESS :
DATE OF BIRTH: 09/12/50
SSAN: 215500399
ORIGINAL X-RAYS REQUESTED
PROVIDE A LIST OF FILMS
FOR PRIOR APPROVAL
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
RECORD CUSTODIAN - COMPLETE AND RETURN
I RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE: I hereby certify that' a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX) :
RECORDS PATIENT BILLING
X-RAYS RECORDS XRAYS have been destroyed
Date Authorized signature for
YORK HOSP
CUMBERLAND
L414004-02
SIGN AND RETURN THIS PAGE
s
t a
THOMAS,THOMAS&HAFER,LLP
I
`! t `i �
John Flounlacker,Esquire C $
Attorney ID#73112 *y� u�
PO Box 999
00;i�;`�. 5 'l�d�, d1t'�
Harrisburg,PA 17108-0999 ��
717-237-7134 Attorneys for Defendant
E-mail:jflounlacker @tthlaw.com
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND CO., PENNSYLVANIA
Plaintiffs
v. NO. 12-5403
JILL R. BRADLEY, CIVIL ACTION — LAW
Defendant
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE TO ISSUANCE OF SUBPOENAS
TO PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
As a prerequisite to service of subpoenas for documents and things pursuant to
Rule 4009.22, Defendant certifies that:
1. A Notice of Intent to Serve Subpoenas, with copies of the subpoenas
attached thereto, was mailed or delivered to each party;
2. A copy of the Notice of Intent, including the proposed subpoenas, is
attached to this Certificate;
3. Twenty(2o) days have passed and no objections have been filed; and
4. The subpoenas which will be served are identical to the subpoenas which
are attached to the Notice of Intent to Serve Subpoenas.
THOMAS, THOMAS &HAFER, LLP
By.
John Flounlacker, Esquire
Attorneys for Defendant
Date: November 12, 2013
THOMAS,THOMAS&HAFER LLP John Flounlacker,Esquire
305 NORTH FRONT STREET Attorney I.D.73112
P.O.BOX 999 717-237-7134
HARRISBURG,PA 17108 Corey J.Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, : CUMBERLAND COUNTY, PA
Plaintiffs,
: NO. 12-5403-Civil
v.
: CIVIL ACTION—LAW
JILL R. BRADLEY, : JURY TRIAL DEMANDED
Defendant,
v. •
•
DEBORAH TILLMAN, •
Defendant. •
NOTICE OF INTENT TO SERVE SUBPOENAS
TO PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Counsel of Record
Defendant Jill R. Bradley intends to serve the 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 objections to these subpoenas. If no objections are made,
the subpoenas will be served.
THOMAS,THOMAS & HAFER,LLP
Date: October 22, 2013 By: 91:il..1.4
JOHN FLOUNLACKER
Attorney for Defendant Jill Bradley
1203429.2
WILLIAM TILLMAN and : IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, : CUMBERLAND COUNTY, PA
Plaintiff(s)
: NO. 12-5403-Civil
V.
: CIVIL ACTION—LAW
JILL R. BRADLEY, : JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Morganstein Defalcis Rehabilitation, 1850 Normandie Drive,York,PA 17408-1534
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a complete copy of all medical treatment records pertaining to William
Tillman (DOB: 09/12/1950) including but not limited to: emergency department records, evaluations,
consultation reports, nursing notes, therapy notes, progress notes, discharge summaries, records of other
health care providers, patient histories, reports of diagnostic studies, correspondence and medical bills
from 2000 to the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party making this request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena,within twenty(20)days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendants
BY THE COURT:
DATE:
Seal of the Court Prothonotary/Clerk, Civil Division
Deputy
THOMAS,THOMAS&HAFER LLP John Flounlacker,Esquire
305 NORTH FRONT STREET Attorney I.D.73112
P.O.BOX 999 717-237-7134
HARRISBURG,PA 17108 Corey J.Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and : IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, : CUMBERLAND COUNTY, PA
Plaintiff(s)
: NO. 12-5403-Civil
V.
: CIVIL ACTION—LAW
JILL R. BRADLEY, : JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Highmark BlueShield,PO Box 890173,Camp Hill,PA 17089
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a complete copy of all information pertaining to William Tillman
(DOB: 09/12/1950; Policy/Certificate No. ZAJ105622665001; Group No.: 03781200) including but
not limited to: claim forms, medical records, medical reports, recorded statements, photographs, bills,
memos, notes and correspondence.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party making this request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena,within twenty(20) days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendants
BY THE COURT:
DATE:
Seal of the Court Prothonotary/Clerk, Civil Division
Deputy
THOMAS,THOMAS&HAFER LLP John Flounlacker,Esquire
305 NORTH FRONT STREET Attorney I.D.73112
P.O.BOX 999 717-237-7134
HARRISBURG,PA 17108 Corey J.Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and : IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, : CUMBERLAND COUNTY, PA
Plaintiff(s)
: NO. 12-5403-Civil
V.
: CIVIL ACTION—LAW
JILL R. BRADLEY, : JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: UHC American Medical Sec.,PO Box 19032,Green Bay,WI 54307-9032
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a complete copy of all information pertaining to William Tillman
(DOB: 09/12/1950; Policy/Certificate No. C04372305; Group No.: 4700009635; Plan Name: Self-
employed) including but not limited to: claim forms, medical records, medical reports, recorded
statements, photographs, bills,memos, notes and correspondence.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party making this request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena,within twenty(20) days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker, Esquire
ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendants
BY THE COURT:
DATE:
Seal of the Court Prothonotary/Clerk, Civil Division
Deputy
CERTIFICATE OF SERVICE
AND NOW, this 22"d day of October 2013, I, DEENA B. MORRISON, a Paralegal in the
law firm of Thomas, Thomas& Hafer, LLP, hereby certify that I sent a true and correct copy of the
foregoing document by placing a copy of the same in the United States Mail, first class, postage
prepaid,to the following:
Andrew C. Spears, Esq.
Handler, Henning& Rosenberg, LLP
1300 Linglestown Road, Suite 2
Harrisburg, Pa 17110
John P. Silli, Esq.
Law Offices of James L. Barlow
900 E. 8`h Avenue, Suite 301
King of Prussia, Pa 19406
4'.6 40'1,LI./.40-14—,
Deena B. Morrison, Paralegal
1203429.2
CERTIFICATE OF SERVICE
I, Deena B. Morrison, a Paralegal for the law firm Thomas, Thomas &Hafer, LLP,
hereby state that a true and correct copy of the attached Certificate Prerequisite was
served upon all counsel of record by first class United States mail, postage prepaid,
addressed as follows, on the date set forth below:
Andrew Spears, Esquire John P. Silli, Esquire
Handler, Henning &Rosenberg, LLP Law Offices of James L. Barlow
1300 Linglestown Road, Suite 2 900 East 8th Avenue, Suite 301
Harrisburg, PA 17110 King of Prussia, PA 19,406
THOMAS, THOMAS &HAFER, LLP
/jamJ 417O`L
Deena B. Morrison, Paralegal
Date: November 12, 2013
1223549.1
THOMAS,THOMAS&HAFER,LLP 2()I4 P D 20
John Flounlacker,Esquire Pt7 3:
Attorney ID#73112 CUQL'RL
PO Box 999 p E f D
Harrisburg,PA 17108-0999 �� YLVAN/i� `I Y
717-237-7134 Attorneys for Defendant
E-mail:jflounlacker @tthlaw.com
WILLIAM TILLMAN and IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, CUMBERLAND CO., PENNSYLVANIA
Plaintiffs
v. NO. 12-5403
JILL R. BRADLEY, CIVIL ACTION — LAW
Defendant
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE TO ISSUANCE OF SUBPOENAS
TO PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
As a prerequisite to service of subpoenas for documents and things pursuant to
Rule 4009.22, Defendant certifies that:
1. A Notice of Intent to Serve Subpoenas, with copies of the subpoenas
attached thereto, was mailed or delivered to each party;
2. A copy of the Notice of Intent, including the proposed subpoenas, is
attached to this Certificate;
3. Twenty(2o) days have passed and no objections have been filed; and
4. The subpoenas which will be served are identical to the subpoenas which
are attached to the Notice of Intent to Serve Subpoenas.
THOMAS, THOMAS &HAFER, LLP
B2-0-4/ ` I-(0"7/
John Flounlacker, Esquire
Attorneys for Defendant
Date: February 18, 2014
1
THOMAS,THOMAS&HAFER LLP John Flounlacker,Esquire
305 NORTH FRONT STREET Attorney I.D.73112
P.O.BOX 999 717-237-7134
HARRISBURG,PA 17108 Corey J.Adamson,Esquire
Attorney I.D.2045008
Attorneys for Defendant
WILLIAM TILLMAN and : IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, : CUMBERLAND COUNTY, PA
Plaintiffs,
: NO. 12-5403-Civil
v.
: CIVIL ACTION—LAW
JILL R. BRADLEY, : JURY TRIAL DEMANDED
Defendant,
•
v.
DEBORAH TILLMAN,
•
Defendant.
NOTICE OF INTENT TO SERVE SUBPOENAS
TO PRODUCE DOCUMENTS AND THINGS FOR
DISCOVERY PURSUANT TO RULE 4009.21
TO: Counsel of Record
Defendant Jill R. Bradley intends to serve a subpoena identical to the one that is attached to
this Notice. You have twenty (20) days from the date listed below in which to file of record and
serve upon the undersigned an objection to this subpoena. If no objections are made, the subpoena
will be served.
• THOMAS,THOMAS &HAFER,LLP
09047 —
Date: January 23, 2014 By:
JOHN FLOUNLACKER
Attorney for Defendant Jill Bradley
1203429.3
p
WILLIAM TILLMAN and : IN THE COURT OF COMMON PLEAS
DEBORAH TILLMAN, his wife, : CUMBERLAND COUNTY, PA
Plaintiff(s)
: NO. 12-5403-Civil
V.
: CIVIL ACTION—LAW
JILL R. BRADLEY, : JURY TRIAL DEMANDED
Defendant(s)
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Dallastown Medical Associates, 1010 Blymire Road,Dallastown,PA 17313
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents or things: a complete copy of all medical treatment records pertaining to William
Tillman (DOB: 09/12/1950) including but not limited to: emergency department records, evaluations,
consultation reports, nursing notes, therapy notes, progress notes, discharge summaries, records of other
health care providers, patient histories, reports of diagnostic studies, correspondence and medical bills
from 2000 to the present.
You may deliver or mail legible copies of the documents or produce things requested by this subpoena,
together with the certificate of compliance, to the party making this request at the address listed above.
You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things
sought. If you fail to produce the documents or things required by this subpoena, within twenty(20)days
after its service,the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: John Flounlacker,Esquire
ADDRESS: P.O.Box 999,Harrisburg,PA 17108-0999
TELEPHONE: (717)237-7134
SUPREME COURT ID#: 73112
ATTORNEY FOR: Defendants
BY THE COURT:
DATE:
Seal of the Court Prothonotary/Clerk, Civil Division
Deputy
CERTIFICATE OF SERVICE
AND NOW, this 23`d day of January 2014, I, DEENA B. MORRISON, a Paralegal in the
law firm of Thomas, Thomas&Hafer, LLP,hereby certify that I sent a true and correct copy of the
foregoing document by placing a copy of the same in the United States Mail, first class, postage
prepaid,to the following:
Andrew C. Spears, Esq.
Handler, Henning&Rosenberg, LLP
1300 Linglestown Road, Suite 2
Harrisburg, Pa 17110
John P. Silli, Esq.
Law Offices of James L. Barlow
900 E. 8th Avenue, Suite 301
King of Prussia, Pa 19406
•
/(_,( //1-a Deena B. Morrison, alegal
al
1203429.3
January 23, 2014
Page 2
I, Andre C'6, Vp Y(, Esquire, counsel for WI)) 0 an a. beburcth T1..I Iin Ow)
do hereby agree to waive the Twenty (20) Day Notice of Intent rule, allowing counsel for
Defendant, Jill Bradley, to issue a subpoena to: Dallastown Medical Associates.
DATE: laciii4
CERTIFICATE OF SERVICE
I, Deena B. Morrison, a Paralegal for the law firm Thomas, Thomas & Hafer, LLP,
hereby state that a true and correct copy of the attached Certificate Prerequisite was
served upon all counsel of record by first class United States mail, postage prepaid,
addressed as follows, on the date set forth below:
Andrew Spears, Esquire John P. Silli, Esquire
Handler, Henning&Rosenberg, LLP Law Offices of James L. Barlow
1300 Linglestown Road, Suite 2 900 East 8th Avenue, Suite 301
Harrisburg, PA 17110 King of Prussia, PA 17406
THOMAS, THOMAS &HAFER, LLP
Deena B. Morrison, aralegal
Date: February 18, 2014
1451726.1
WILLIAM TILLMAN : COURT OF COMMON,PLEAS
AND : CUMBERLAND COUNTY
DEBORAH TILLMAN, HIS WIFE
Plaintiff,
v.
JILL R. BRADLEY
V.
DEBORAH TILLMAN
DEFENDANT
Defendant. .• NO. 12-5403
cn
STIPULATION
It is hereby stipulated and agreed upon by all counsel that the counter -claim against
Deborah Tillman is dismissed with prejudice and Deborah Tillman is removed from this action
as a Defendant. The parties further agree that the within Stipulation may be filed in counterparts.
THOMAS, THOMAS & HAFER, LLP
LAW OFFICES OF JAMES L. BARLOW
r
JOHN FLOUNLACKER, ESQUIRE JO ESQUIRE
Attorney for Defendant, Jill R. Bradley
HANDLER, HENNING & ROSENBERG, LLP
Attorney for Defendant, Deborah Tillman
ANDREW C. SPEARS, ESQUIRE
Attorney for Plaintiffs, William and Deborah Tillman
otivd, 1.9.sepi
msb
R-iTL 3oFt-tqs
.41
WILLIAM TILLMAN : COURT OF COMMON PLEAS
AND : CUMBERLAND COUNTY
DEBORAH TILLMAN, HIS WIFE
Plaintiff,
v.
ALL R. BRADLEY
DEFENDANT
V.
DEBORAH TILLMAN
Defendant. : NO. 12-5403
STIPULATION
It is hereby stipulated and agreed upon by all counsel that the counter -claim against
Deborah Tillman is dismissed with prejudice and Deborah Tillman is removed from this action
as a Defendant. The parties further agree that the within Stipulation may be filed in counterparts.
THOMAS,. T OMAS & .HAFER, LLP
JOHN F OUNLACKER, ESQUIRE
Attorney for Defendant, Jill R. Bradley
HANDLER, HENNING & ROSENBERG, LLP
LAW OFFICES OF JAMES L. BARLOW
JOHNTP. SILLI, ESQUIRE
Attorney for Defendant, Deborah. Tillman
ANDREW C. SPEARS, ESQUIRE
Attorney for Plaintiffs., William and Deborah Tillman
THOMAS, THOMAS & HAFER, LLP
305 NORTH FRONT STREET
P.O. BOX 999
HARRISBURG, PA 17108
(717)237-7100
Attorneys for Jill R. Bradley
WILLIAM TILLMAN and
DEBORAH TILLMAN, his wife
Plaintiffs
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
: NO. 12 -5403 -Civil
: CIVIL ACTION — LAW
JILL R. BRADLEY, : JURY TRIAL DEMANDED
Defendant
v.
DEBORAH TILLMAN,
Defendant
PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please withdraw the appearance of John Flounlacker, Esquire as counsel for Defendant
Jill R. Bradley.
Date:
TO THE PROTHONOTARY:
THOMAS, THOMAS & HAFER, LLP
John Flounlacker, Esquire
I.D. No. 73112
Please enter the appearance of John F. Yaninek, Esquire on behalf of Defendant Jill R.
Bradley.
Date:
THOMAS, THOMAS & HAFER, LLP
Jo Yaninek,wire
I. t o. 55741
CERTIFICATE OF SERVICE
I, April L. Casper, a secretary with the law firm of Thomas, Thomas & Hafer, LLP,
hereby certify that I have, this day, served a true and correct copy of the foregoing Praecipe for
Withdraw/Entry of Appearance upon the person and at the address listed below by placing a
copy of same in the United States 1st Class Mail, postage prepaid, to the following:
Andrew C. Spears, Esquire
Handier, Henning & Rosenberg, LLP
1300 Linglestown Road, Suite 2
Harrisburg, Pa 17110
John P. Silli, Esquire
Law Office of James L. Barlow
900 East 8th Avenue, Suite 301
King of Prussia, PA 19406
Date: 'j I
THOMAS, THOMAS & HAFER, LLP
By:
AprilViA
. Casper, Legal Scretary
pc,
2