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HomeMy WebLinkAbout12-7679~~ ~~'E FR~TNQ~NO'T~R~. 2112 DEC 2 I P~ 3~ 06 Y R. J. MARZELI.A 8c ASSOCI~;~~C~:'~"`~~~ BY: Robin J. Marzell~, Esquire Pennsylvania Supreme Court I.D. No. 66856 Attorney for 3513 North Front Street Karen Kreitzer and Harrisburg, PA t7tto Steven Kreitzer Telephone: (7t7) i34-78z8 Facsimile• ~t~133a 688 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Karen and Steven Kreitzer ~ ~ i' • / ~ I t9o Alters Road DOCKET NO. ~- V Carlisle, PA t7ot5 Plaintiffs v. Carlisle Regional Medical Center 36t Alexander Spring Road Carlisle, PA t7ot5 Healing Arts Surgical Associates t Tyler Court, Suite z Carlisle, PA t7ot5 Richard Griffiths, D.O. ~ Tyler Court, Suite z Carlisle, PA t7ot5 Defendants CIVIL ACTION JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons in the above-captioned action. ~ Writ of Summons shall be issued and forwarded to ()Attorney (X) Sheriff ~ ~,,, ~ `~/~ ~S ~,u"~ ~~~ ~~ .,~~ gt{SC~ ~ Robin J. Marzella, Esquire 353 North Front Street Harrisburg, PA ~7~~0 (7~7) 234-7828 Robin J. Marzel Es uire Supreme Court ID No. 66856 Date: /~~~,~~~~ 7 R. J. MARZELLA & ASSOCIATES, P.C. BY: Robin J. Marzella, Esquire Pennsylvania Supreme Court I.D. No. 66856 Attorney for 353 North Front Street Karen Kreitzer and Harrisburg, PA ~7~~o Steven Kreitzer Telephone: (7~7) 234-7828 Facsimile• (7») 2~ 4.688.3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Karen and Steven Kreitzer ~ ~`~ ~~ v l ~9o Alters Road DOCKET NO. Carlisle, PA i7o~5 Plaintiffs CIVIL ACTION v. Carlisle Regional Medical Center 36~ Alexander Spring Road Carlisle, PA ~70~5 Healing Arts Surgical Associates ~ Tyler Court, Suite z. Carlisle, PA ~7ot5 Richard Griffiths, D.O. ~ Tyler Court, Suite z. Carlisle, PA ~7oi5 Defendants JURY TRIAL DEMANDED WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS CO MENCED AN ACTION AGAINST YOU. Pr thonotary , D 1R U Z 0 ~ . 13 ~V~- Date: 'o'ff- ~~'1.- t~„ _ by Deputy ( )Check here i# reverse is used for additional information. TMflNO M. E. ANf1?23 ""JAN-8 CUPIp?SA1"LVANIA TY HENRY & BEAVER LLP By: Wiley P. Parker, Esquire Identification No. 20653 Amy B. Leonard, Esquire Identification No. 93526 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 Attorneys for Richard Griffiths, D.O. and Healing Arts Surgical Associates KAREN AND STEVEN KREITZER, IN THE COURT OF COMMON PLEAS Plaintiffs CUMBERLAND COUNTY, PENNYSLVANIA CIVIL ACTION LAW - MEDICAL V. CARLISLE REGIONAL MEDICAL. ACTION NO. 12-7679 CENTER, HEALING ARTS SURGICAL ASSOCIATES, and, JURY TRIAL DEMANDED RICHARD GRIFFITHS, D.O., Defendants PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearances of Wiley P. Parker, Esquire, and Amy B. Leonard, Esquire, of the law firm of Henry & Beaver LLP, whose address is 937 Willow Street, P.O. Box 1140, Lebanon, Pennsylvania 17042-1140, as attorneys for Richard Griffiths, D.O. and Healing Arts Surgical Associates, the Defendants in the above-captioned matter. Dated: (' ,fi ,1f.r + 4 2C "J HENRY & BEAVER LLP WILEY P. PfRRER, Esquire I.D. #20653 tt 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 (Phone) (717) 274-6782 (Fax) parker@henrybeaver.com Attorney for Defendants Richard Griffiths, D.O. and Healing Arts Surgical Associates HENRY & BEAVER LLP By: C j1j.,,J7z:L - f ?- ..") L ONARD D # 26 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 (717) 274-3644 (Phone) (717) 274-6782 (Fax) leonard@henrybeaver.com Attorney for Defendants Richard Griffiths, D.O. and Healing Arts Surgical Associates CERTIFICATE OF SERVICE I, Wiley P. Parker, of the firm of Henry & Beaver LLP, do hereby certify that I served a certified true and correct copy of the within Praecipe for Entry of Appearance upon the following person(s) on January I , 2013 in the manner specified below: Name Manner of Service Robin Marzella, Esquire U.S. First Class Mail MARZELLA & ASSOCIATES 3513 North Front Street Harrisburg, PA 17110 Date: January 2013 WILEY P. PARKER MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN FILED-OFFICE AB By: Crag A. Stone, Esquire Attorney I.D. No. 15907 2013'APR 15 PIS 1; 4 1 By: Michael C. Mongiello, Esquire CUMBERLAND CDUl 'Y Attorney I.D. No. 87532 PENNSYLVANIA Crums Mill Road Harrisburg, PA 17112 Telephone: (717) 651-3704 mcmon ]g'eilogmdwcg com Attorney for Defendants, Carlisle Regional Medical Center KAREN AND STEVEN KREITZER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs NO. 12-7679 V. CIVIL ACTION—LAW CARLISLE REGIONAL MEDICAL CENTER, HEALING ARTS SURGICAL ASSOCIATES JURY TRIAL DEMANDED AND RICHARD GRIFFITHS,D.O., Defendants PRAECIPE TO FILE STIPULATION OF COUNSEL TO LIMIT PLAINTIFFS' VICARIOUS LIABILITY CLAIM TO THE PROTHONOTARY: Kindly file of record the attached Stipulation of Counsel to Limit Plaintiffs' Vicarious Liability Claim in the above-referenced matter. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN Date: kiA By: Michael C lo, Esquire I.D. No. 875 2 4200 Crums Mill Road Harrisburg, PA 17112 (717) 651-3704 Attorney for Defendant Carlisle Regional Medical Center 05/1030709.v 1 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document has been served upon the following known counsel and parties of record this 12th day of April, 2013, via United States First-Class Mail, postage prepaid: Robin J. Marzella, Esquire R. J. Marzella& Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Wiley P. Parker, Esquire Henry & Beaver, LLP 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 MARSHAL 4E, EY, WARNER COLEMAN BY: Mi 1 C. ngiello, Esquire 05/1030709.vl MARSHALL, DENNEHEY, WARNER, COLEMAN& GOGGIN By: Craig A. Stone,Esquire Attorney I.D.No. 15907 By: Michael C. Mongiello, Esquire Attorney I.D.No. 87532 4200 Crums Mill Road Harrisburg, PA 17112 Telephone: (717) 651-3704 mcmon ig'ellokmdwcg com Attorney for Defendant, Carlisle Regional Medical Center KAREN AND STEVEN KREITZER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs NO. 12-7679 V. CIVIL ACTION a LAW CARLISLE REGIONAL MEDICAL CENTER, HEALING ARTS SURGICAL ASSOCIATES JURY TRIAL DEMANDED AND RICHARD GRIFFITHS,D.O., Defendants STIPULATION OF COUNSEL TO LIMIT PLAINTIFFS' VICARIOUS LIABILITY CLAIM AND NOW come Plaintiffs,Karen and Steven Kreitzer("Plaintiffs"), by and through their counsel,Robin J. Marzella,Esquire; and Defendant, Carlisle Regional Medical Center ("CRMC"), by and through its counsel, Michael C. Mongiello, Esquire; and hereby stipulate and agree as follows: 1. Counsel executing this Stipulation hereby represent and warrant that they are authorized to do so by their respective clients and their representatives and insurers, if any. 2. Plaintiffs'vicarious liability claim against CRMC is based solely on the conduct of alleged agent/servant and co-Defendant general surgeon, Richard Griffiths, D.O. and any other alleged CRMC agent/servant who may have been involved in the laparoscopic o cholecystectomy performed on patient-Plaintiff, Karen Kreitzer on December 31, 2010, as may be identified in discovery proceedings. 3. This Stipulation may be executed in counterparts and shall be considered effective when executed on behalf of all parties. 4. Facsimile or photocopy reproduction of signatures shall have the effect of original signatures. IN WITNESS WHEREOF,the parties,by their counsel,have caused this Stipulation to be executed and intend to be legally bound thereby. 16113 o in J. a, ire Mich a ngiello,Esquire R. J. Marze a&Associates, P.C. Marshall,De ehey, Warner, Coleman 3513 North Front Street &Goggin Harrisburg, PA 17110 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 05/1025595.v1 i� MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN By: Craig A. Stone, Esquire -e c.- rn Attorney I.D. No. 15907 7- _ i By: Michael C. Mongiello, Esquire � ��-;� Attorney I.D. No. 87532 `1't � --+ ' 4200 Crums Mill Road Harrisburg, PA 17112 �z C�o Telephone: (717) 65173704 mcmon ig ello(? ,mdwcg.corn w Attorney for Defendant, Carlisle Regional Medical Center KAREN AND STEVEN KREITZER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 12-7679 V. CIVIL ACTION—.LAW CARLISLE REGIONAL MEDICAL CENTER, HEALING ARTS SURGICAL ASSOCIATES JURY TRIAL DEMANDED AND RICHARD GRIFFITHS, D.O., Defendants NOTICE TO PLEAD To: Plaintiffs Karen and Steven Kreitzer c/o Robin J. Marzella, Esquire R. J. Marzella& Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be filed against you. MARSHAL DE EHEY, WARNER NX COLEMAN rGIN BY: Crai t e, Esquire Mich WIC C ongiello, Esquire 4200 Crums Mill Road Harrisburg, PA 17112 MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN By: Craig A. Stone, Esquire Attorney I.D. No. 15907 By: Michael C. Mongiello, Esquire Attorney I.D. No. 87532 4200 Crums Mill Road Harrisburg, PA 17112 Telephone: (717) 651-3704 mcmongiello a,mdwc com Attorney for Defendant, Carlisle Regional Medical Center KAREN AND STEVEN KREITZER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 12-7679 V. CIVIL ACTION —LAW CARLISLE REGIONAL MEDICAL CENTER, HEALING ARTS SURGICAL ASSOCIATES JURY TRIAL DEMANDED AND RICHARD GRIFFITHS, D.O., Defendants ANSWER AND NEW MATTER TO PLAINTIFFS' AMENDED COMPLAINT OF DEFENDANT, CARLISLE REGIONAL MEDICAL CENTER AND NOW, comes Defendant, Carlisle Regional Medical Center (hereinafter referred to as "CRMC" or "Answering Defendant") by and through its counsel, Marshall, Dennehey, Warner, Coleman & Goggin, and answers and asserts New Matter to Plaintiffs' Amended Complaint as follows: 1. Denied. CRMC is advised by counsel and therefore avers that the corresponding. averments of Plaintiffs' Amended Complaint do not pertain to it and that no further answer is required. 2. Denied as stated. At all relevant times, Carlisle HMA, LLC d/b/a CRMC operated a medical facility licensed under the laws of the Commonwealth of Pennsylvania with a business office of 361 Alexander Spring Road, Carlisle, Cumberland County, Pennsylvania, 1.7015. 3-4. Denied. CRMC is advised by counsel and therefore avers that the corresponding averments of Plaintiffs' Amended Complaint do not pertain to it and that no further answer is required. 5. Denied. It is specifically denied that co-Defendant Richard Griffiths, D.O. (hereinafter "Dr. Griffiths") was at any time relevant an employee of CRMC. With regard to Plaintiffs' allegations regarding unidentified staff members, agents, apparent agents, ostensible agents and servants, CRMC is without information sufficient to respond, said allegations are specifically denied and strict proof thereof is demanded at the time of trial to the extent relevant. The Stipulation of Counsel to limit Plaintiffs' vicarious liability claim, filed of record on April 15, 2013, is hereby incorporated by reference as if fully set forth herein at length. Finally, the corresponding averments of Plaintiffs' Amended Complaint are denied as conclusions of law to which no responsive pleading is required. 6-44. Admitted in part and denied in part. It is admitted that patient-Plaintiff, Karen Kreitzer had progressively worsening shortness of breath over the two (2) years prior to February 2011 as alleged. The remaining corresponding averments of Plaintiffs' Amended Complaint are denied by operation of Pa. R.C.P. 1029(e) and/or as conclusions of law to which no responsive pleading is required. By way of further answer, CRMC was not negligent. To the contrary, at all relevant times, CRMC directly and indirectly, met or exceeded the standard of care and at no time caused or contributed to the injuries as alleged. Finally, the Stipulation of Counsel to limit Plaintiffs' vicarious liability claim, filed of record on April 15, 2013, is hereby incorporated by reference as though fully set forth herein at length. COUNT NEGLIGENCE Karen Kreitzer V. Richard Griffiths, D.O. 45. CRMC hereby incorporates by reference the answers contained in paragraphs 1 through 44 above as though fully set forth herein at length. 46-52. Denied. ,CRMC is advised by counsel and therefore avers that the corresponding averments of Plaintiffs' Amended Complaint do not pertain to it and that no further answer is required. WHEREFORE, Defendant, Carlisle Regional Medical Center demands judgment in its favor and against Plaintiffs. COUNT II INFORMED CONSENT Karen Kreitzer V. Richard Griffiths, D.O. 53. CRMC hereby incorporates by reference the answers contained in paragraphs 1 through 52 above as though fully set forth herein at length. 54-56. Denied. CRMC is advised by counsel and therefore avers that the corresponding averments of Plaintiffs' Amended Complaint do not pertain to it and that no further answer is required. By way of further answer, as a matter of law, CRMC cannot be vicariously liable for the alleged failure to obtain informed consent by Dr. Griffiths, WHEREFORE, Defendant, Carlisle Regional Medical Center demands judgment in its favor and against Plaintiffs. COUNT III VICARIOUS LIABILITY Karen Kreitzer V. Carlisle Regional Medical Center 57. CRMC hereby incorporates by reference the answers contained in paragraphs 1 through 56 above as though fully set forth herein at length. 58-64. Denied. The corresponding averments of Plaintiffs' Amended Complaint are denied by operation of Pa. R.C.P. 1029(e) and/or as conclusions of law to which no responsive pleading is required. By way of further answer, CRMC was not negligent. To the contrary, at all relevant times, CRMC, directly and indirectly, met or exceeded the standard of care and at no time caused or contributed to the injuries as alleged. With regard to Plaintiffs' allegations regarding unidentified actual or ostensible agents, servants and employees, CRMC is without information sufficient to respond, said allegations are specifically denied and strict proof thereof is demanded at the time of trial to the extent relevant. Finally, the Stipulation of Counsel limiting Plaintiffs' vicarious liability claim, filed of record on April 15, 2013, is hereby incorporated by reference as though fully set forth herein at length. WHEREFORE, Defendant, Carlisle Regional Medical Center demands judgment in its favor and against Plaintiffs. COUNT III VICARIOUS LIABILITY Karen Kreitzer V. Healing Arts Surgical Associates 65. CRMC hereby incorporates by reference the answers contained in paragraphs 1 through 64 above as though fully set forth herein at length. 66-72. Denied. CRMC is advised by counsel and therefore avers that the corresponding averments of Plaintiffs' Amended Complaint do not pertain to it and that no further answer is required. To the extent that an answer may be deemed required, it is specifically denied that Dr. Griffiths was an employee of CRMC. With regard to Plaintiffs' allegations regarding unidentified actual or ostensible agents, servants or employees, CRMC is without information sufficient to respond, said allegations are specifically denied and strict proof thereof is demanded at the time of trial to the extent relevant. By way of further answer, the corresponding averments of Plaintiffs' Amended Complaint are denied as conclusions of law to which no responsive pleading is required. Finally, the Stipulation of Counsel limiting Plaintiffs' vicarious liability claim, filed of record on April 15, 2013, is hereby incorporated by reference as though fully set forth herein at length. WHEREFORE, Defendant, Carlisle Regional Medical Center demands judgment in its favor and against Plaintiffs. NEW MATTER 73. CRMC hereby incorporates by reference the answers contained in paragraphs 1 through 72 above as if fully set forth herein at length. 74. Plaintiffs' Complaint fails to state a claim upon which relief can be granted against Answering Defendant. 75. At no time relevant hereto was any other natural person, partnership, corporation or other legal entity acting or serving as an agent, servant, employee or otherwise for or on behalf of Answering Defendant. 76. At all times relevant hereto, Answering Defendant, and its agents and servants, complied with the applicable standard of care. 77. At all times relevant hereto, Answering Defendant acted within and followed the precepts of a respected school of thought and, accordingly, all professional conduct was fully commensurate with the applicable standard of care. Evidence at trial may establish two or more schools of thought applicable to the issues presented in this case. 78. Patient - Plaintiff assumed the risk of injury and this action is therefore barred by the Doctrine of Assumption of Risk. 79. Answering Defendant believes and therefore avers that evidence accumulated through discovery and provided at trial may establish that patient - Plaintiff was contributorily or comparatively negligent, and in order to protect the record, Answering Defendant hereby pleads contributory or comparative negligence as an affirmative defense. 80. Answering Defendant is entitled to relief and contribution in accordance with the Pennsylvania Comparative Negligence Act, 42 P.S. § 7102 as amended by Senate Bill 1089, effective August 14, 2002. 81. In the event that it is determined that Answering Defendant was negligent with regard to any of the allegations contained in, and with respect to Plaintiffs' Amended Complaint, said allegations being specifically denied, said negligence, if any, was superseded by the intervening negligent acts of other person, parties and/or organizations other than Answering Defendant and over whom Answering Defendant had no control, right, responsibility and, therefore, Answering Defendant is not liable. 82. Any acts or omissions of Answering Defendant alleged to constitute negligence were not substantial causes, factual causes, or factors contributing to the injuries and damages alleged in Plaintiffs' Amended Complaint. 83. Plaintiffs' injuries and losses, if any, were not caused by the conduct or negligence of Answering Defendant, but rather, were caused by pre-existing medical conditions and/or causes beyond the control of Answering Defendant, and Plaintiffs may not recover against it. 84. Some or all of Plaintiffs' claims are barred by operation of the applicable statute of limitations, including 42 Pa. C.S.A. § 5524 and 40 P.S. § 1301.605. 85. All.claims that might have been asserted by Plaintiffs, including claims for medical expenses and/or any claim by husband-Plaintiff, are barred by operation of the applicable statute of limitations. 86. Plaintiffs' claims are limited and barred by Section 103, 602 and 606 of the Health Care Services Malpractice Act of 1974, 40 P.S. § 1301, et sec., as amended. 87. Plaintiffs' claims are limited and barred by the provisions of the Medical Care Availability and Reduction of Error (MCARE) Act, 40 P.S. § 1303.101, et seq. 88. The damages alleged by Plaintiffs did not result from acts or omissions of Answering Defendant, its agents, servants or employees, but, rather, from acts or omissions of persons and/or entities over whom Answering Defendant had no right of control. 89. Pa. R.C.P. 238 is unconstitutional on its face and as may be applied in this case. 90. Plaintiffs' claims, the existence of which are specifically denied by Answering Defendant, may be reduced and/or limited by any collateral source of compensation and/or benefit in accordance with the Pennsylvania Supreme Court decision in Moorhead v. Crozer Chester Medical Center. 91. For the purposes of preserving the same, and subject to discovery, all or some of Plaintiffs claims may be barred pursuant to the affirmative defenses of release, offset, accord or satisfaction. 92. Upon information and belief, and subject to discovery, the injuries and damages alleged to have been sustained by patient-Plaintiff were the result of pre-existing conditions or natural causes, and not the result of any action or inaction of Answering Defendant. 93. The alleged injury to patient-Plaintiff can occur in the absence of negligence. 94. Plaintiffs cannot sufficiently eliminate other responsible causes for patient- Plaintiffs alleged injury, including the conduct of patient-Plaintiff herself and/or of third persons. 95. The facts of this case do not support pursuit of a theory of res ipsa loquitor and Plaintiffs have failed to state a claim in this regard. 96. There is no vicarious liability for an alleged failure to obtain informed consent, as to CRMC, as a matter of law. 97. Answering Defendant demands trial by jury on all issues. WHEREFORE, Defendant, Carlisle Regional Medical Center demands judgment in its favor and against Plaintiffs. MARSHA , DE EHEY, WARNER COLEMA GGIN BY: Crag , one, Esquire I.D. No. 1 907 Michael C. Mongiello, Esquire I.D. No. 87532 4200 Crums Mill Road Harrisburg, PA 17112 Date: 05/1028955.v1 VERIFICATION I hereby affirm that the following facts are correct: Carlisle Regional Medical Center is a Defendant in the foregoing action and i am authorized to execute this Verification on their behalf. The attached Answer with New Matter is based upon information which has been gathered by my Counsel in the defense of this lawsuit. The language of the Answer with New Matter is that of Counsel and not of me. I have read the Answer with New Matter and to the extent that the contents of the Answer with New Matter are that of counsel, they are true and correct to the best of my knowledge,information and belief. To the extent that the contents of the objections and answers are that of Counsel,I have relied upon Counsel in making this Verification. i hereby acknowledge that the facts set forth in the aforesaid objections and answers are made subject to the penalties of 1$ PA C.S. § 4904, relating to unsworn falsification to authorities. CARLISLE REGIONAL MEDICAL CENTER By: Amy Bei 1 r, BSN, N Director of Risk Management and Patient Safety Officer 05110281M.v 1 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document has been served upon the following known counsel and parties of record this 21st day of June, 2013, via United States First-Class Mail, postage prepaid: Robin J. Marzella, Esquire R. J. Marzella& Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Wiley P. Parker, Esquire Henry & Beaver, LLP 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 MARSHAL JHEY, WARNER COLEMA BY: Mic ael o i llo, Esquire 05/1028955.v 1 R.J. MARZELLA&ASSOCIATES, P.C. BY: Robin J. Marzella, Esquire Pennsylvania Supreme Court I.D. No. 66856Attorney for 3513 North Front Street Karen Kreitzer and Harrisburg, PA 17110 Steven Kreitzer Telephone: (717) 234-7828 Facsimile: (717) 234-6883 « c_ IN THE COURT OF COMMON PLEAS r� ;� CUMBERLAND COUNTY, PENNSYLVANIA � , c� + Karen and Steven Kreitzer DOCKET NO. 12-7679 C) C7 c- Plaintiffs CIVIL ACTION V. Carlisle Regional Medical Center; Healing Arts Surgical Associates; and Richard Griffiths, D.O., Defendants JURY TRIAL DEMANDED PLAINTIFFS' RESPONSE TO DEFENDANT, CARLISLE REGIONAL MEDICAL CENTER'S ANSWER TO COMPLAINT WITH NEW MATTER 73. No response is required. 74. Denied. It is specifically denied that Plaintiffs' Complaint fails to state a claim upon which relief can be granted against Answering Defendant. 75. Denied. It is specifically denied that at no time relevant hereto was any other natural person, partnership, corporation or other legal entity acting or serving as an agent, servant, employee or otherwise for or on behalf of Answering Defendant. 76. Denied. It is specifically denied that at all times relevant hereto, Answering Defendant, and its agents and servants, complied with the applicable standard of care. 77. Denied. It is specifically denied that at all times relevant hereto, Answering Defendant acted within and followed the precepts of a respected school of thought and accordingly, all professional conduct was fully commensurate with the applicable standard of care. It is further specifically denied that the evidence at trial may establish two or more schools of thought applicable to the issues presented in this case. 78. Denied. It is specifically denied that Patient/Plaintiff assumed the risk of injury and this action is therefore barred by the Doctrine of Assumption of Risk. 79. Denied. It is specifically denied that evidence accumulated through discovery and provided at trial may establish that Patient/Plaintiffwas contributorily or comparatively negligent, and in order to protect the record, Answering Defendant hereby pleads contributory or comparative negligence as an affirmative defense. 80. Denied. It is specifically denied that Answering Defendant is entitled to relief and contribution in accordance with the Pennsylvania Comparative Negligence Act, 42 P.S. § 7102 as amended by Senate Bill 1089, effective August 14, 2002. 81. Denied. It is specifically denied that in the event it is determined that Answering Defendant was negligent with regard to any of the allegations contained in, and with respect to Plaintiff's Amended Complaint, said negligence was superseded by the intervening negligent acts of other person, parties, and/or organizations other than Answering Defendant and over whom Answering Defendant had no control, right, responsibility and therefore, Answering Defendant is not liable. 82. Denied. It is specifically denied that any acts or omissions of Answering Defendant alleged to constitute negligence were not substantial causes, factual causes, or factors contributing to the injuries and damages alleged in Plaintiffs'Amended Complaint. 83. Denied. It is specifically denied that Plaintiffs' injuries and losses were not caused by the conduct or negligence of Answering Defendants, but rather were caused by pre-existing medical conditions and/or causes beyond the control of Answering Defendant and Plaintiff may not recover against it. 84. Denied. It is specifically denied that some or all of Plaintiffs' claims are barred by operation of the applicable statute of limitations, including 42 Pa. C.S.A. § 5524 and 40 P.S. § 1301.605. 85. Denied. It is specifically denied that all claims that might have been asserted by Plaintiffs, including claims for medical expenses and/or any claim by husband-Plaintiff, are barred by the operation of the applicable statute of limitations. 86. Denied. It is specifically denied that Plaintiffs claims are limited and barred by Section 103, 602, and 606 of the Health Care Services Malpractice Act of 1974, 40 P.S. § 1301, et sect., as amended. 87. Denied. It is specifically denied that Plaintiffs' claims are limited and barred by the provisions of the Medical Care Availability and Reduction of Error (MCARE)Act, 40 P.S. § 1303.101, et se_g. 88. Denied. It is specifically denied that the damages alleged by Plaintiffs did not result from acts or omissions of Answering Defendant, its agents, servants or employees, but rather, from acts or omissions of persons and/or entities over whom Answering Defendant had no right of control. 89. Denied. It is specifically denied that Pa. R.C.P. 238 is unconstitutional on its face and as may be applied in this case. 90. Denied. It is specifically denied that Plaintiffs' claims may be reduced and/or limited by any collateral source of compensation and/or benefit in accordance with the Pennsylvania Supreme Court decision in Moorhead v. Crozer Chester Medical Center. 91. Denied. It is specifically denied that all or some of Plaintiffs' claims may be barred pursuant to the affirmative defenses of release, offset, accord, or satisfaction. 92. Denied. It is specifically denied that the injuries and damages alleged to have been sustained by Patient/Plaintiff were the result of pre-existing conditions or natural causes, and not the result of any action or inaction of Answering Defendant. 93. Denied. It is specifically denied that the alleged injury to Patient/Plaintiff can occur in the absence of negligence. 94. Denied. It is specifically denied that Plaintiffs cannot sufficiently eliminate other responsible causes for Patient/Plaintiffs alleged injury, including the conduct of Patient/Plaintiff herself and/or of third persons. 95. Denied. It is specifically denied that the facts of this case do not support pursuit of the theory of Fes ispa loquitor.. It is further specifically denied that Plaintiffs have failed to state a claim in this regard. 96. Denied. It is specifically denied that there is no vicarious liability for an alleged failure to obtain informed consent, as to CRMC, as a matter of law. 97. No response is required. Respectfully submitted, R.J. &ASSOCIATES,P.C. ROB LA., Es IRE ID No.66 DATED: CERTIFICATE OF SERVICE I, Cynthia M. von Schlichten, hereby certify that a true and correct copy of the Plaintiffs Response to Defendant, CRMC's New Matter, was served upon counsel of record this 1 st day of July, 2013, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania,postage prepaid, first class delivery, and addressed as follows: Michael Mongiello, Esq. Marshall Dennehey 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Wiley Parker, Esq. Henry &Beaver 937 Willow Street Lebanon, PA 17042-1140 R.J.MARZELLA&ASSOCIATES,P.C. r / BY: �/, (/' Cynt '' M. von Schlichten,Esquire MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN • � =J f h ? ;�^f r By: Craig A. Stone, Esquire '. �� P 3 , Attorney I.D. No. 15907 311 By: Michael C. Mongiello, Esquire U?BERL ,D O r&� Attorney I.D. No. 87532 PENNSYLVANIA 4200 Crums Mill Road Harrisburg, PA 17112 Telephone: (717) 651-3704 mcmongiello @mdwcg.com Attorney for Defendant, Carlisle Regional Medical Center KAREN AND STEVEN KREITZER, IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs • NO. 12-7679 v. • CIVIL ACTION—LAW CARLISLE REGIONAL MEDICAL CENTER, : HEALING ARTS SURGICAL ASSOCIATES JURY TRIAL DEMANDED AND RICHARD GRIFFITHS, D.O., Defendants • PRAECIPE FOR CHANGE OF ADDRESS TO THE PROTHONOTARY: Please note the change of address of counsel for Defendant, Carlisle Regional Medical Center from 4200 Crums Mill Road, Suite B, Harrisburg, PA 17112 to: Craig A. Stone, Esquire Michael C. Mongiello, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 100 Corporate Center Drive, Suite 201 Camp Hill, PA 17011 MARSHALL, iJ 1 EHEY, WARNER COLEMAN :4 f• IN BY: Date: October 28, 2013 Mich.-1Tl T ongiello, Esquire 05/1122588 v l 4 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document has been served upon the following known counsel and parties of record this 28th day of October, 2013, via United States First-Class Mail, postage prepaid: Robin J. Marzella, Esquire R. J. Marzella& Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Wiley P. Parker, Esquire Henry & Beaver, LLP 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 MARSHALL, I ►■E EY, WARNER COLEMAN & 0(.0' BY: 11 Mich. irir angiello, Esquire 05/1122588.v l max. ] ix Jy . 201'-1 MAR 17 CUMBERLAND COUNTY KAREN AND STEVEN KREITZER, PENNSYllL 'AI`NRCOURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA i'iU_- H O.tio r Plaintiffs v. CARLISLE REGIONAL MEDICAL CENTER, HEALING ARTS SURGICAL ASSOCIATES AND RICHARD GRIFFITHS, D.O., NO. 12 -7679 CIVIL ACTION — LAW JURY TRIAL DEMANDED Defendants WITHDRAWAL OF APPEARANCE AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of the undersigned on behalf of Defendant, Carlisle Regional Medical Center in the above - captioned case. MARSHA'I;,IiEI. COLEMA 1 : • BY: NIA,- i17 . ongiello, Esquire II 100 • • r p .rate Center Drive, Suite 201 Cam' Hill, PA 17011 EHEY, WARNER GGIN Telephone: (717) 651 -3704 ENTRY OF APPEARANCE Please enter the appearance of the undersigned on behalf of Defendant, Carlisle Regional Medical Center in the above - captioned case. Date: j/0# GROSS MCG BY: Andrew H. ' als n, Jr., Esquire I.D. No. 88770 33 South 7th Street Allentown, PA 18105 Telephone: (610) 820 -5450 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document has been served upon the following known counsel and parties of record this /2"day of March, 2014, via United States First-Class Mail, postage prepaid: Robin J. Marzella, Esquire R. J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Wiley P. Parker, Esquire Henry & Beaver, LLP 937 Willow Street P.O. Box 1140 Lebanon, PA 17042-1140 GROSS MCG BY: 05/1179571,v1 Andrew n, Jr., Esquire CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL C) r - Ga As a prerequisite to service of a subpoena for documents and things pl suant to Rule 4009.22 - ri Co, rn ▪ � 't 7.7. rl Cd1 L _< y:> t O CD i .‹; C7 r -I 37' C) _d,; D ^r? 2: cMCS on behalf of HOWARD STEVENS, ESQ. —cam C7 r_i? CD certifies that r' y= (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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS HO A D STEVENS, ESQ. Atro !ey for DEFENDANT MCS # 17104-LO1 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: DEAN MURTAGH, ESQ., PLAINTIFF COUNSEL ROBIN J. MARZELLA, ESQ., PLAINTIFF COUNSEL MCS on behalf of HOWARD STEVENS, ESQ. 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 the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. DATE: 08/18/2014 CC: HOWARD STEVENS, ESQ. - CHS KREITZER DEAN MURTAGH, ESQ. GERMAN, GALLAGHER & MURTAGH, P.C. 200 SOUTH BROAD STREET SUITE 500 PHILADELPHIA, PA 19102 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 17104-0O2 DE02 LOCATION NAME »> LOCATION LIST «< PAGE: 1 RECORDS REQUESTED CUMBERLAND COUNTY AGING & COMM DR. DARRYL GUISTWITE HARRISBURG ORTHOPEDIC ASSOC CARLISLE DIGEST. DISEASE ASSOC DR. FRANKLIN MYERS GERARD J. CRINER, M.D. MOFFIT HEART & VASCULAR GROUP BEN FRANKLIN JR/SR HIGH SCHOOL CMS, PHILADELPHIA REGIONAL OFF MEDICAID -CUMBERLAND COUNTY CARLISLE AREA HIGH SCHOOL EMPLOYMENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS SCHOLASTIC MEDICARE HEALTH INSURANCE SCHOLASTIC MCS # 17104-0O2 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of -Records for CUMBERLAND COUNTY AGING & COMMUNITY SERVICES (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 RIDER **** at The MCS Group. Inc. 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the docuinents 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY T COURT: Arir IlArcono ary/r lerk, Civil Division Deputy 17104-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND COUNTY AGING & COMMUNITY SERVICES 1100 CLAREMONT ROAD CARLISLE. PA 17015 RE: MCS # 17104-L01 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Any and all employment records,including applications, files, memoranda. compensation. disciplinary actions: time and attendance records. Please include personnel records. W2 forms. payroll and salary information. Supply all employee medical records including any disability, workers compensation. or incident reports and claims. This should contain all records in your possession. all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic_form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L01 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L02 DEll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. DARRYL GUISTWITE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered bythe court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court /11111114/ ProlliM.FCCIe k, rivil Division BY THECOURT: Deputy 17104-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. DARRYL GUISTWITE 522 S. PITT STREET CARLISLE, PA 17013 RE: MCS # 17104-L02 KAREN KREITZER. 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records. physical therapy records files. memoranda, handwritten notes. emails, phone messages. history, physical reports. Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts. all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L02 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L03 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG ORTHOPEDIC ASSOC (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 RIDER **** at The MCS Group. Inc., 1601 Market Street Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: _ Seal of the Court BY TH Pro C erk, ivi Division Deputy - I- 17104-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG ORTHOPEDIC ASSOC 450 POWERS AVE. HARRISBURG, PA 17109 RE: MCS # 17104-L03 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 0842-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files. memoranda, handwritten notes. emails, phone messages, history, physical reports. Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts. all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L03 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L04 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian -of -Records for CARLISLE DIGEST. DISEASE ASSOC. (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 RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA I 9103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN. PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: _ Seal of the Court BY THE C Pro honota Civil Division Deputy 17104-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE DIGEST. DISEASE ASSOC. 241 ALEXANDER SPRING RD. CARLISLE. PA 17015 RE: MCS # 17104-L04 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L04 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L05 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. FRANKLIN MYERS (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 A 1-1ACHED RIDER **** at The MCS Group, Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY T AS )3 IMP211 Prothonotary/Clerk ivil Division Deputy 17104-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. FRANKLIN MYERS 1631 N. FRONT STREET HARRISBURG, PA 17102 RE: MCS # 17104-L05 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports. Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts. all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L05 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L06 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GERARD J CR1NER, M.D. (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 RIDER **** at The MCS Group. Inc,. 1601 Market Street. Suite 800. Philadelphia PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BYTHP 4.19if • / Pro "IrPotat Clerk, 11 Division Deputy 17104-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GERARD J. CRINER, M.D. 3401 N. BROAD STREET 7TH FLOOR ZONE C PHILADELPHIA, PA 19140 RE: MCS # 17104-L06 KAREN KREITZER 190 ALTERS ROAD CARLISLE,- PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files. memoranda, handwritten notes, emails, phone messages, history, physical reports, Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts. all archived records, or records in storage. Including any and all items as.may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L06 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MOFFIT HEART & VASCULAR GROUP (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 RIDER. **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST, ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COU T: /Clerk, •ivil Division Deputy 17104-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MOFFIT HEART & VASCULAR GROUP 360 ALEXANDER SPRING ROAD CARLISLE. PA 17013 RE: MCS # 17104-L07 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L07 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L08 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BEN FRANKLIN JR/SR HIGH SCHOOL (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 RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court 1,0 BY THE COURT: ,—j4IJ Prot l�i .ta ,/' ler', • vil Division Deputy 17104-08 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: BEN FRANKLIN JR/SR HIGH SCHOOL 351 MORGANTOWN STREET UNIONTOWN, PA 15401 RE: MCS # 17104-L08 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire scholastic file, including but not limited to files, memoranda, correspondence, notes, and records relating to admission, attendance. student history, and any transfers. Include all grades, merit awards. disciplinary actions, medical and physical records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L08 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L09 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian ofRecords for CMS. PHILADELPHIA REGIONAL OFF (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 RIDER **** at The MCS Group. Inc_ 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN. PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court Pro ono ICLerk, Civ 1 Division Deputy 17104-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CMS, PHILADELPHIA REGIONAL OFF 150 SOUTH INDEPENDENCE MALL WEST STE 272 PHILADELPHIA, PA 19106 RE: MCS # 17104-L09. KAREN KREITZER 190 ALTERS ROAD CARLISLE,- PA 17013 Social Security #: 000-00-2679 Date of Birth: 08-02-1956 Any and all medicare claims and other information related to any injury/illness, including benefits, medical records, services, payments, providers, correspondence, eligibility and personal health information. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L09 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L10 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MEDICAID -CUMBERLAND COUNTY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court o produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800, Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN. PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court Pro notary/Clerk, Civil Division Deputy 17104-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MEDICAID -CUMBERLAND COUNTY 33 WESTMINSTER DRIVE CARLISLE, PA 17013 RE: MCS # 17104-L10 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide any and all records, pertaining to the member. Include all claims, claim notices, appeals, payments and reimbursements. Supply any and all medical records, reports, prescription and pharmacy records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as maybe stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L10 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/09/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-Lil DE11 COMMO- NWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian'of Records for CARLISLE AREA HIGH SCHOOL (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 RIDER **** at The MCS Group. Inc., 1601 Market Street. Suite 800 Philadelphia PA 19103 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 pr'oduce 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY TH k T: Prothonotary ler , f iv' Division Deputy 17104-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE AREA HIGH SCHOOL 623 W. PENN STREET CARLISLE. PA 17013 RE: MCS # 17104-L11 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social. Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire scholastic file, including but not limited to files, memoranda, correspondence, notes, and records relating to admission, attendance, student history, and any transfers. Include all grades, merit awards, disciplinary actions, medical and physical records. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L11 SU10 • CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things44 to Rule 4009.22 11 MCS on behalf of HOWARD STEVENS, ESQ. --r- •• 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/28/2014 M D STEVENS, ESQ. ney for DEFENDANT MCS # 17104-L12 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL BILLING ONLY TO: ROBIN J. MARZELLA, ESQ., PLAINTIFF COUNSEL WILEY PARKER, ESQ. MCS on behalf of HOWARD STEVENS, ESQ. 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 the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. DATE: 10/06/2014 CC: HOWARD STEVENS, ESQ. CHS KREITZER ROBIN J. MARZELLA, ESQ. MARZELLA & ASSOCIATES 3513 N. FRONT ST. HARRISBURG, PA 17110 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 17104-0O3 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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 RIDER * * at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST, ALLENTOWN PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY T i OURT: a k, Civil Division Deputy 17104-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG. PA 17101 RE: MCS # 17104-L12 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: 000-00-2679 Date of Birth: 08-02-1956 Please provide the entire hospital medical file, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Including any and all laboratory & office/admission charts. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L12 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KAREN & STEVEN KREITZER COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/28/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L13 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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 RIDER **** at The MCS Group, Inc.. 1601 Market Street, Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: 1//A4 Pro 1.0 .147 Cle , Civil Division Deputy 17104-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL BILLING DEPARTMENT 111 S. FRONT STREET HARRISBURG. PA 17105 RE: MCS # 17104-L13 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: 000-00-2679 Date of Birth: 08-02-1956 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L13 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL C")) r m W As a prerequisite to service of a subpoena for documents and thing rsuant--T, to Rule 4009.22• N▪ CTa �� Mo ..- MC S MCS on behalf of HOWARD STEVENS, ESQ. '-`{ -G 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/11/2014 MC D ST VENS, t orney for DEFENDANT MCS # 17104-L14 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DR. KENNETH GUISTWITE MEDICAL RECORDS & BILLING TO: ROBIN J. MARZELLA, ESQ., PLAINTIFF COUNSEL WILEY PARKER, ESQ. MCS on behalf of HOWARD STEVENS, ESQ. 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 the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. DATE: 10/20/2014 CC: HOWARD STEVENS, ESQ. - CHS KREITZER ROBIN J. MARZELLA, ESQ. MARZELLA & ASSOCIATES 3513 N. FRONT ST. HARRISBURG, PA 17110 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 17104-0O3 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. KENNETH GUISTWITE (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 RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN. PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: 449 Seal of the Court BY THE C S URT: notary/Clerk, •ivil Division Deputy 17104-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. KENNETH GUISTWITE 522 S. PITT STREET CARLISLE. PA 17013 RE: MCS # 17104-L14 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical and billing file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, emails, phone messages, history, physical reports and all prescriptions records. Including any laboratory & office/admission charts. Including but not limited to, This should contain all records in your possession, all office and admission charts, :all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L14 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 D ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL rTr.• As a prerequisite•to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2014 MC D STE ENS, ESQ. rney for DEFENDANT MCS # 17104-L16 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: KAREN & STEVEN KREITZER -VS- CARLISLE REGIONAL MEDICAL CENTER, ET AL COURT OF COMMON PLEAS TERM, CASE NO: 12-7679 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DR. CHO STUART A. HARTMAN, D.O. CARLISLE EAR NOSE & THROAT ORTHOPEDIC INSTITUTE OF PA MEDICAL RECORDS & RADIOLOGY MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS & RADIOLOGY TO: ROBIN J. MARZELLA, ESQ., PLAINTIFF COUNSEL WILEY PARKER, ESQ. MCS on behalf of HOWARD STEVENS, ESQ. 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 the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. DATE: 11/03/2014 CC: HOWARD STEVENS, ESQ. ROBIN J. MARZELLA, ESQ. MARZELLA & ASSOCIATES 3513 N. FRONT ST. HARRISBURG, PA 17110 - CHS KREITZER MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 17104-0O3 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER File No. 12-7679 vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. CHO (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 RIDER * * * * at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: lac" v NOV 25 2014 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 17104-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. CHO REHAB MEDICINE ASSOCIATES 5124 E. TRINDLE ROAD MECHANICSBURG, PA 17050 RE: MCS # 17104-L16 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical and diagnostic film file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, emails, phone messages, history and physical reports. Including any and all laboratory & office/admission charts. Supply all medication and prescription records. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG'S, EMG'S, MRI'S, and x-ray and all corresponding reports or inventories. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L16 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L17 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for STUART A. HARTMAN, D.O. (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 RIDER at The MCS Group. Inc.. 1601 Market Street, Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN, PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY THE COURT: fal4tz:L) Prothonotary/Clerk, Civil Division ./ NOV 25 2014 Deputy 17104-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STUART A. HARTMAN, D.O. 341 CUMBERLAND STREET FIRST FLOOR LEBANON, PA 17042 RE: MCS # 17104-L17 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L17 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L18 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE EAR NOSE & THROAT (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 RIDER The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia, PA 19103 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: HOWARD STEVENS, ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTO , PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: NOV 25 2014 Seal of the Court BY THE COURT: • Prothonotary/Clerk, Civil Division 17104-18 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE EAR NOSE & THROAT 9 BROOKWOOD AVENUE CARLISLE, PA 17015 RE: MCS # 17104-L18 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L18 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KAREN & STEVEN KREITZER TERM, CUMBERLAND -VS- CASE NO: 12-7679 CARLISLE REGIONAL MEDICAL CENTER, ET AL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of HOWARD STEVENS, ESQ. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/25/2014 MCS on behalf of HOWARD STEVENS, ESQ. Attorney for DEFENDANT MCS # 17104-L19 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPEDIC INSTITUTE OF PA (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 RIDER * * * * i' ur .i .1 u,_ e." - 111 .1- so :. 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: HOWARD STEVENS. ESQ. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN. PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: phq /1( NOV 251014 Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division 17104-19 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA 3399 TRINDLE ROAD CAMP HILL, PA 17011 RE: MCS # 17104-L19 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical and diagnostic film file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten records and notes, emails, phone messages, history and physical reports. Including any and all laboratory & office/admission charts. Supply all medication and prescription records. Provide all diagnostic films and tests, including CAT scans, CT scans, EEG's EKG'S, EMG'S, MRI'S, and x-ray and all corresponding reports or inventories. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L19 SU10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KAREN & STEVEN KREITZER vs. CARLISLE REGIONAL MEDICAL CENTER, ET AL : File No. 12-7679 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPEDIC INSTITUTE (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 RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: HOWARD STEVENS, ESO. ADDRESS: 33 SOUTH 7TH ST. ALLENTOWN. PA 18105 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: io(.2-7 I Seal of the Court BY THE URT: otary/Clerk, Ci 11 Division Deputy 17104-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE 450 POWERS AVENUE LOWER LEVEL HARRISBURG, PA 17109 RE: MCS # 17104-L15 KAREN KREITZER 190 ALTERS ROAD CARLISLE, PA 17013 Social Security #: XXX -XX -2679 Date of Birth: 08-02-1956 Please provide entire medical file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records files, memoranda, handwritten notes, emails, phone messages, history, physical reports, Laboratory & office/admission charts, and all prescriptions records. This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items asmay be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $100.00 for hospitals, $150.00 for all other providers. MCS # 17104-L15 SU10