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Home My WebLink About12-6704Stephen G. Held, Esquire Attorney ID# 72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Raad, Suite 2 Harrisburg, PA 1711(! Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Held@hhrlaw.com F' ii i, '~ .;t,•i, Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~1 No. 2012 ___~~. ~U ~:1 `[`~,r ~ Civil Action (>CX) Law Sandra Bowman Robert E. Wolf M.D. 1100 Columbus Avenue WatersEdge Apt. 4 1857 Center Street Lemoyne, PA 17043 Camp Hill, PA 17011 versus and Cosmetic Surgery by Wolf, P.C. 6260 Stirrip Court Harrisburg, PA 17111 Plaintiff & Address Defendants & Addresses PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X_ Wnt of Summons Shall be issued and forwarded to ( )Attorney (XX)Sheriff Stephen G. Held Esquire Handler. Henning & Rosenberg LLP ; ' 1300 Linglestown Road, Suite 2 _ ~" ; l_~ ~~ Harrisburg PA 17110 -- - --- Sign t~ uCe ' ' `te~~ney X17 238-2000 _ Supreme Court ID IVo. 72663 ,i-'° NamerAddress/Telephone No. of Atto~ ney Date: October 24, 2012 ~~S'.~ Q~~~1c,3~~ a Ck~~ ~ zs~ ~~~ a~asc~y 3732886746.1-C2L LAW OFFICES OF TWANDA TURNER- HAWKINS ATTORNEY FOR DEFENDANT(S) LAURIE B. TILGHMAN,ESQ. Robert E. Wolf Identification No. 89936 7535 Windsor Drive, Suite 101-B Allentown,PA 18195 Telephone: (610) 398-5492 SANDRA BOWMAN, COURT OF COMMON PLEAS `� _, OF DeiffilN COUNTY � _ -- Plaintiff, b) t - NO. CV-2012-6704 ' --71 vs. n;, N) ROBERT E. WOLF, .<-s -0 .�- C? ,. -c- Defendant. = c.a •t NOTICE OF DEPOSITION TO: Stephen G. Held, Esq. Handler, Henning&Rosenberg, LLP 1300 Linglestown Rd Ste 2 Harrisburg, PA 17110 PLEASE TAKE NOTICE that the undersigned attorney will take the deposition by oral examination of: NAME: Sandra Bowman DATE: Friday, February 7, 2014 TIME: 10:00 A.M. LOCATION 1300 Linglestown Rd Ste 2, Harrisburg, PA You are invited to attend and cross-examine, if you so desire. ` Z- ___77/. LAURIE . TICtAN, ESQ. � Attorney or Defendant(s) i ii Robert E. Wolf Dated: Wednesday, October 23, 2013 3732886746.1-C2L LAW OFFICES OF TWANDA TURNER- HAWKINS ATTORNEY FOR DEFENDANT(S) LAURIE B. TILGHMAN,ESQ. Robert E. Wolf Identification No. 89936 7535 Windsor Drive, Suite 101-B Allentown, PA 18195 Telephone: (610) 398-5492 SANDRA BOWMAN, COURT OF COMMON PLEAS OF DAUPHIN COUNTY ca - Plaintiff, =; NO. CV-2012-6704 ` ' vs. r•-) rte ; -. ROBERT E. WOLF, xp.(--) = w Defendant. _; 1N1 CERTIFICATE OF SERVICE I, Laurie B. Tilghman, Esquire, hereby certify that a true and correct copy of the attached Deposition Notice directed to Plaintiff, Sandra Bowman, was served this date by United States Mail, First Class, postage prepaid, upon: Stephen G. Held, Esq. Handler, Henning &Rosenberg, LLP 1300 Linglestown Rd Ste 2 Harrisburg, PA 17110 Cumberland County Court of Common Pleas Office of the Prothonotary 1 Courthouse Square, Suite 100 Carlisle, PA 17013 4 AURIE B. 7JILGHMAN, ESQ. ; 1 Attorney for Defendant(s) Robert E. Wolf Date: Wednesday, October 23, 2013 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE: NOTIFIF_D THAT THE ABO\/E-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST Y'OU. ~ --~, ~ _ ~ ,ti ; ~ r./~. Prothonotary Date ...___~ ~ ~ Deputy (;heck here if reverse is used for additional information PROTHON 55 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~,u~p;,+ i~ana~r~~r r ~~ s' , L. ~ e.~ l.1 d' s' t 1..., L~I2 ~'0"~ 21 P~ 2~ 3~ CUM~L~L~I~~ L0~13~i J '' P~'~P~SYl.~'i~~lA Sandra Bowman vs. Case Number Robert E. Wolf, MD (et al.) 2012-6704 SHERIFF'S RETURN OF SERVICE 11/05/2012 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Cosmetic Surgery by Wolf, PC, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Writ of Summons according to law. 11/13/2012 01:56 PM -Deputy William Cline, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Denise Peabody, Office Manager, who accepted as "Adult Person in Charge" for Robert E. Wolf, MD at 18 Center Street, East Pennsboro Township, Camp Hill, PA 17011. LLIA CLINE, D UTY 11/14/2012 The requested Writ of Summons served by the Sheriff of Dauphin County upon Carolyn Wolf, who accepted for Cosmetic Surgery by Wolf, PC, at 6260 Stirrip Court, Harrisburg, PA 17111. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $62.00 SO ANSWERS, ----~.. November 16, 2012 RON R ANDERSON, SHERIFF Shelle~ Ruhl Real Esta a Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Jack Duignan ;~~: Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County 101 Mazket Street Harrisburg, Pennsylvania 17101-2079 ph:(7l7)780-6590 fax: (717)255-2889 Jack Lotwick Sheriff SANDRA BOWMAN VS COSMETIC SURGERY BY WOLF, P.C. Sheriff s Return No. 2012-T-2929 OTHER COUNTY NO. 2012-6704 And now: NOVEMBER 14, 2012 at 8:25:00 AM served the within WRIT OF SUMMONS upon COSMETIC SURGERY BY WOLF, P.C. by personally handing to CAROLYN WOLF 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 6260 STIRRUP COURT HARRISBURG PA 17111 OWNER OF DEFENDANT Sworn and subscribed to before me this 15TH day of November, 2012 ~~ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Ex fires Au ust 17, 2014 So Answers, Sheriff of,,H,~~I,in C Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $47.25 11/13/2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY w 'BOWMAN Vs. NO. CV2012 6704 WOLF CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 LAURIE B TILGHMAN, 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: 05/07/14 MLR File #: M420935 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 610-398-5480 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTION, rINC 4940 DISSTON STREET 'e�- 17 _. PHILADELPHIA PA 19135 m cz -- (215) 335-3581 -"-- -,,7 By: Chelsea Torres v.,r" M, -,,''__' r~ o, z CD' r. C3 ,-.__. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY BOWMAN WOLF Vs. TO: STEPHEN HELD, ESQ (PLAINTIFF) No. CV2012 6704 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 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 objction to the subpoena. If no objection is made the subpoena may be served, Date: 04/16/14 Enc(s): Copy of subpoena(s) Counsel return card File #: M420935 LAURIE B TILGHMAN, ESQUIRE 7535 WINDSOR DR SUITE 101-B ALLENTOWN, PA 18195 ATTORNEY FOR DEFENDANT INQUIRII S SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3581 By: Chelsea Torres BOWMAN Vs. WOLF PENNSYTWANTA courry OF CUM33ERIAND File No. CV2012 6704 SUBPOENA TO PRODUCE DOCUMENTS ENTS OR THINGS FOR D I SCOVERY PURSUANT TO RULE 4009.22 HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL PA 17011 TO: ATTN: MEDICAL RECORDS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you Are produce the following documents orr ng , ordered till) ADDENDUM by the court to at MEDICAL LEGAL REPRODUCTIONS(A Nts11940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested t; this subpoena, together with the certificate of compliance, to the party making thi request at the address listed above. You have the right to seek in advance the rea,3onable 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 th i r, subpoena may seek a court orde- carpelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LAURIE B TILGHMAN, ESQ ADDRESS: A 1.11 • R TELEPHONE: 215-335-3212 SUPREME COURT ID # ATTORNEY FOR: M420935-01 DATE: DEFENDANT R 18195 THEODRT: .Cs - Prothonot r y/C1er~k, Civil Division SYaI of tla he•rt `�-- „=4 -��-C--�.:.-- = ezt_ ` Deputy (Eff. 7/97) BOWMAN Vs. WOLF ADDENDUM TO SUBPOENA No. CV2012 6704 CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSP ANY AND ALL INPATIENT, OUTPATIENT AND ER RECORDS DATED 11/18/10. PERTAINING TO: NAME: SANDRA BOWMAN ADDRESS: 1100 COLUMBUS AVE APT 1 LEMOYNE PA DATE OF BIRTH: 05/17/43 SSAN: XXXXX6222 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] 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 CUMBERLAND M420935-01 HOLY SPIRIT HOSP * * * SIGN AND RETURN THIS PAGE * * BC)WMAN WOLF COMMONWEALTH OF FENNg u;-:= ' COUNTY OF CUMBERLAND Vs. File No. CV2012 6704 ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TRISTAN ASSOCS, 240 GRANDVIEW AVE, CAMP HILL PA 17011 TO: (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered produce the •following documents orthings: Inv the court to at MEDICAL LEGAL REPRODUCTIONS (A itst940 DISSTON ST., PHILA., PA You may deliver or mail legible copies'of the documents or produce things requested t --:y this subpoena, together with the certificate of compliance, to the party making th i request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or prydLC s nC the thinga- sought. If you .fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving th i ; subpoena may seek a court orde+- caipe l l ing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLL.CWING PERSON: NAME: LAURIE B TILGHMAN, ESQ ADDRESS: 7535 WINDSOR DR TELEPHONE: PA 18195 215-335-3212 SUPREME COURT ID # ATTORNEY FOR: DEFENDANT M420935-02 DATE: 4QQ2ta ( , 1 0 Sell of the Court Aa Prothonotary/C 1 erk , Civil Division Deputy (Eff. 7/97)' ADDENDUM TO SUBPOENA BOWMAN • Vs. WOLF CUSTODIAN OF RECORDS FOR: TRISTAN ASSOCS **SEE ATTACHED ADDENDUM** PERTAINING TO: No. CV2012 6704 NAME: SANDRA BOWMAN ADDRESS: 1100 COLUMBUS AVE APT 1 LEMOYNE PA DATE OF BIRTH: 05/17/43 SSAN: XXXXX6222 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS AREATTACMED IIERETO: 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 CUMBERLAND 'M420935-02 TRISTAN ASSOCS * * * SIGN AND RETURN THIS PAGE ADDENDUM Tristan Associates Any and all diagnostic studies involving the Left and Right Shoulder. Include corresponding radiology reports, completed patient registration, history and insurance forms. All diagnostic studies preferred on CD. ID # 1553450 Stephen G. Held Attorney ID# 72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Held@hhrlaw.com Attorney for Plaintiff(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SANDRA BOWMAN, Plaintiff(s) v. ROBERT E. WOLF, M.D. and COSMETIC SURGERY BY WOLF, P.C., Defendant(s) 2012-6704 Civil Action - Law MOTION TO COMPEL DISCOVERY Plaintiff, Sandra Bowman ("Ms. Bowman"), by and through her attorneys, HANDLER, HENNING & ROSENBERG, LLP, hereby moves this Honorable Court to compel Defendant, Robert E. Wolf ("Defendant"), to file complete and responsive Answers to Plaintiffs' Second Set of Interrogatories. In support thereof: 1. Ms. Bowman is an adult individual currently residing at 1102 Columbus Avenue, Apt. 9, Lemoyne, Cumberland County, Pennsylvania. 2. Defendant is, upon information and belief, an adult individual with a business address of 1857 Center Street, Camp Hill, Cumberland County, Pennsylvania. 3: Plaintiff has retained Stephen G. Held, Esq., of HANDLER, HENNING, & ROSENBERG, LLP, as legal counsel for a liability suit against Defendant. 4. Defendant has retained Laurie B. Tilghman, Esq., of THE LAW OFFICES OF KENNETH S. O'NEILL, 7535 Windsor Drive, Suite 101-B, Allentown, PA, 18195; phone number (610) 398-5492; fax number (610) 398-5481. 5. On or about January 31, 2013, Plaintiff filed her Complaint in the Court of Common Pleas of Cumberland County. 6. On or about March 8, 2013, Defendant, filed an Answer and New Matter and New Matter Cross-Claims, to which Plaintiffs replied on March 14, 2013. 7. On or about June 11, 2014, Plaintiff's counsel sent, via first-class United States mail, Discovery in the form of Interrogatories ("Discovery Requests") to Defendant. 8. Pursuant to Pa. R.C.P. No. 4006(2), the party answering Interrogatories "shall serve a copy of the answers, and objections if any, within 30 days after service ...." 9. Pursuant to Pa. R.C.P. No. 4009.12(a), "[t]he party upon whom the request is served shall within thirty days after service of the request (1) serve an answer including objections to each numbered paragraph in the request, and (2) produce or make available to the party submitting the request those documents and things described in the request to which there is no objection." 10. Defendant's responses to Plaintiff's Discovery Requests should have been answered on or before July 11, 2014. 11. On September 8, 2014, approximately two months after Defendant's original responses were due, Plaintiff's counsel sent Defendant's counsel a letter requesting responses 2 to Plaintiff's Discovery Requests or an explanation as to why such response had not been and could not be provided. A copy of Plaintiff's Letter is attached as Exhibit "A". 12. Plaintiff did not receive a response. 13. Plaintiff had contacted Defense Counsel and reminded her to provide Discovery responses, which no responses were received. 14. Plaintiff believes and, therefore, avers that, in accordance with Pa. R.C.P. No. 4005(c), the Discovery Requests would not cause unreasonable annoyance, embarrassment, oppression, burden, or expense to any person or party. 15. Plaintiff believes and, therefore, avers that the information that could be gained by responses to her Discovery Requests is necessary and vital in order to properly litigate this case. 16. As of the date of this Motion to Compel, Plaintiff has yet to receive a single response to her Discovery Requests directed to Defendant, despite the fact that approximately five months have elapsed since the service of said Discovery Requests. 17. Plaintiffs counsel has contacted Defendant's legal counsel, Laurie B. Tilghman, Esq., on several occasions regarding this matter and as yet has not been able to reach any agreement on this matter. 18. To complete discovery and move this action forward expeditiously, Plaintiff respectfully submits this Motion to Compel Discovery. 19. Assuming, arguendo, that this Honorable Court does not grant this Motion, Plaintiff respectfully requests a discovery conference. 20. This matter has not yet been assigned to a Judge for disposition. 3 WHEREFORE, Plaintiff, Sandra Bowman, respectfully requests that this Honorable Court issue an Order compelling Defendant, Robert E. Wolf, to file responses to Plaintiff's Discovery in the form of Interrogatories within ten (10) days of the date of such an Order. Dated: Dec. J3, 2014 By: Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Step " en G. HId (PA 72663) Attorneys for Plaintiff, Sandra Bowman 4 Stephen G. Held Attorney ID# 72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Held@hhrlaw.com Attorney for Plaintiff(s) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SANDRA BOWMAN, Plaintiff(s) 2012-6704 v. Civil Action - Law ROBERT E. WOLF, M.D. and COSMETIC SURGERY BY WOLF, P.C., Defendant(s) CERTIFICATE OF SERVICE On, December 23, 2014, hereby certify that a true and correct copy of Motion to Compel Discovery was served upon the following by depositing same in the United States Mail, in Harrisburg, Pennsylvania: Laurie B. Tilghman, Esq. Law Offices of Kenneth S. O'Neill 7535 Windsor Drive Suite 101-B Allentown, PA 18195 Attorney for: Robert E. Wolf, M.D. HANDLER, HENNING & ROSENBERG, LLP SANDRA BOWMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION — LAW ROBERT E. WOLF, M.D., and COSMETIC SURGERY BY WOLF, P.C., Defendants • : NO. 12-6704 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL DISCOVERY ORDER OF COURT AND NOW, this 31st day of December, 2014, upon consideration of Plaintiffs Motion To Compel Discovery, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Christ ee L. Peck, en G. Held, Esq. 1300 Linglestown Road Suite 2 Harrisburg, PA 17110 Attorney for Plaintiff ie B. Tilghman, Esq. The Law Offices of Kenneth O'Neill 7535 Windsor Drive, Suite 101-B Allentown, PA 18195 Attorney for Defendants :rc Ces /Y& LFIL /;./3 lily =11 -7.73 • r— < CD