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HomeMy WebLinkAbout13-0250~- ,~ , Christina L. Bradley, Esquire ~"- °`, t ~ #~ FREEBURN 8v HAMILTON ~ ~~ ~~_~i! ~~~` _ k ~' ,r~~-. ..,,_ ID No. 89107 ~~~~~A~'~ 2040 Linglestown Road, Suite 300 ~-'~~ +{ ~' = P~tflT~ Harrisburg PA 17110 (717) 671-1956 Z~)3 OAK ~ S Ph4 ~ ~ ~ $ christinabu ~~_injui-~~la~~~-er.com ~~~`R~~;~p ~~~~Qt`t9rney for Plaintiffs t iT COURTNEY MOTES, EUGENE MOTES AND TRICIA MOTES, Plaintiffs ~. GIANT FOOD STORES, LLC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~o.: ~ 3-asv c~~~i CIVIL ACTION -LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 Dated: o ~a.~..,.~ 1 ~r.. 2a i3 Christina L. Bradley, squire Attorneys for Plaintiff Q~~ ~~ag.~s~~Q~l C~ ~ ~ Ste' ~,~~ Y Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road, Suite 300 Harrisburg PA 17110 (717) 671-1955 christinab~u r~-irliurvla~n~~er.com Attorney for Plaintiffs COURTNEY MOTES, EUGENE MOTES IN THE COURT OF COMMON PLEAS AND TRICIA MOTES, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. NO.. GIANT FOOD STORES, LLC, Defendant. CIVIL ACTION -LAW NOTICE LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted quiere defenderse de estas demandas expuestas e~ las paginas siguientes, usted tiene viente (20) Bias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar ua apariencia esrita o en persona o por abogado y archivar en la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notifcacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LISTED DEBE LLBVAR ESTATE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEQUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 Dated: ~ t ~ _ Christina L. Bradley, E ire Attorneys for Plaintiff Christina L. Bradley, Esquire FREEBURN &; HAMILTON ID No. 89107 2040 Linglestown Road, Suite 300 Harrisburg PA 17110 (717) 671-1955 christinabiu ua -iniuryla«~~er.com Attorney for Plaintiffs COURTNEY MOTES, EUGENE MOTES IN THE COURT OF COMMON PLEAS AND TRICIA MOTES, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. NO.. GIANT FOOD STORES, LLC, CIVIL ACTION -LAW Defendant. COMPLAINT AND NOW come Plaintiffs, Courtney Motes, Eugene Motes, and Tricia Motes, by their attorneys, Freeburn 8v Hamilton, and file the following Complaint: 1. Plaintiff, Courtney Motes, is an adult individual who resides at 279 Susquehanna Avenue, East Pennsboro Township, Cumberland County, Pennsylvania. 2. Plaintiffs, Eugene Motes and Tricia Motes, husband and wife, are adult individuals who reside at 279 Susquehanna Avenue, East Pennsboro Township, Cumberland County, Pennsylvania. 3. Defendant, Giant Food Stores, LLC, is a Delaware Limited Liability Corporation, with its Corporate Headquarters located at 27 Brookwood Avenue, Carlisle, Cumberland County, Pennsylvania. 4. The facts and occurrences hereinafter related took place on or about July 31, 2011, at approximately 1'0:45 p.m. inside Giant Food Stores, located at 310 East Penn Drive, Enola, Cumberland County, Pennsylvania (hereinafter "Giant Enola"). 5. At that time and place, Defendant was in exclusive possession, management and control of the interior of Giant Enola through its employees who were acting within the scope and course of their employment by Defendant, and in furtherance of Defendant's business. 6. At that time and place, Plaintiff, Courtney Motes, was a business visitor at Giant Enola. 7. At that time and place, Plaintiff, Courtney Motes, was walking in the frozen food aisle of Giant Enola. 8. At that time and place, an employee of Giant Enola was in the process of stocking the freezer with ice cream. 9. At that time and place, the box from which the Giant Enola employee was taking the ice cream was leaking a foreign substance unknown to Plaintiff, Courtney Motes, but believed to be either melted ice cream or water from melted ice. 10. This foreign, unknown, melted substance caused Plaintiff, Courtney Motes, to slip and fall. 11. The foregoing incident and all of the injuries and damages as set forth hereinafter are the direct and proximate result of the negligent, gross negligence, careless, wanton and reckless manner in which Defendant operated and maintained the Giant Enola as follows: a. In failing to exercise reasonable care to ensure the safety of business visitors such as Plaintiff; b. In failing to inspect the premises and discover the foreign substance that caused the incident; c. In failing to discover and/or keep the premises and floor of Giant Enola free and clear of foreign substances that would create a hazard to business visitors such as Plaintiff; d. In failing to adequately supervise and manage its employees who should have discovered and removed the foreign substance that caused the incident; e. In failing to anticipate the harm that the foreign substance would cause business visitors; f. In permitting a foreign substance to accumulate on the floor at a point where it posed an unreasonable risk of injury to Plaintiff and other business visitors; g. In failing.. to give warning of the dangerous condition posed by the accumulation of the foreign substance, erect barricades, or take any other safety precautions to prevent injury to Plaintiff and other business visitors; and h. In failing to remove the foreign substance from the floor and keep the floor clean and free of hazardous conditions. COUNT I -- NEGLIGENCE Courtney Motes, Plaintiff v. Giant Food Stores, LLC, Defendant 12. Paragraphs 1-11 are incorporated herein by reference thereto. 13. As a result of Defendant's negligence, carelessness and recklessness, Plaintiff, Courtney Motes, suffered painful and severe injuries to her nerves, bones and soft tissues, which include, but are not limited to, her head, right elbow and right knee. 14. By reason of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has suffered a heightened possibility that she will suffer other or additional injury in the future, and claim is made therefore. 15. The aforesaid injuries suffered by Plaintiff, Courtney Motes, may have aggravated or been aggravated by an existing infirmity, condition or disease, resulting in a prolongation or worsening of the injuries and an enhanced risk of future harm to Plaintiff, and claim is made therefore. 16. By reason of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she was forced to incur liability for reasonable and necessary medical tests, medical examinations, medical treatment, medications, hospitalizations and similar expenses in an effort to diagnose her injuries and to restore herself to health, and claim is made therefore. 17. Plaintiff, Courtney Motes, has not fully recovered from her injuries and it is reasonably likely that she will incur similar expenses in the future, and claim is made therefore. 18. By reason of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has suffered a loss of earnings and earning capacity and is entitled to recover the value of the time, earnings and employment benefits she has lost and which she might reasonably have earned in the pursuit of her ordinary calling, and claim is made therefore. 19. By reason of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has suffered a loss or impairment of future earning capacity, and claim is made therefore. 20. By reason of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has incurred incidental costs and expenses, the exact amount of which cannot be ascertained at this time, and claim is made therefore. 21. As a result of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has undergone and in the future will undergo great physical and mental pain and suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 22. As a result of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has been subjected to humiliation, embarrassment, shame, worry and anger. 23. As a result of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has been subjected to severe mental anguish, emotional distress, nervous shock, fright and horror. 24. As a result of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she will continue to endure great mental anguish, emotional distress, shame, worry and anger in the future. 25. By reason of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has been deprived her enjoyment of the pleasures of life. 26. Plaintiff, Courtney Motes, continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefore. 27. As a result of the aforesaid injuries suffered by Plaintiff, Courtney Motes, she has suffered a disfigurement., and claim is made therefore. WHEREFORE, Plaintiff, Courtney Motes, demands judgment in her favor and against Defendant, Giant Food Stores, LLC, in an amount in excess of FIFTY THOUSAND 8v 00/ 100 ($50,000.00) DOLLARS, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. COUNT II Eugene Motes, Plaintiff v. Giant Food Stores. LLC, Defendant 28. Paragraphs 1-27 are incorporated herein by reference thereto. 29. At the time of the incident herein referred, Plaintiff, Courtney Motes, was a minor, born October 12, 1994. 30. As a result of the injuries suffered by his minor daughter, Courtney Motes, Plaintiff, Eugene Motes, has incurred expenses and/or liability for the reasonable and necessary medical tests, medical examinations, medical treatment, medications, medical care, hospitalizations and similar expenses in an effort to diagnose and treat her injuries, and claim is made therefore. WHEREFORE, Plaintiff, Eugene Motes, demands judgment in his favor and against Defendant, Giant Food Stores, LLC, for compensatory damages in an amount in excess of FIFTY THOUSAND 8s 00/ 100 ($50,000.00) DOLLARS, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. f'~AiTNT iii Tricia Motes, Plaintiff v. Giant Food Stores, LLC, Defendant 31. Paragraphs 1-30 are incorporated herein by reference thereto. 32. At the time of the incident herein referred, Plaintiff, Courtney Motes, was a minor, born October 12, 1994. 32. As a result of the injuries suffered by her minor daughter, Courtney Motes, Plaintiff, Tricia Motes, has incurred expenses and/or liability for the reasonable and necessary medical tests, medical examinations, medical treatment, medications, medical care, hospitalizations and similar expenses in an effort to diagnose and treat her injuries, and claim is made therefore. WHEREFORE, Plaintiff, Tricia Motes, demands judgment in her favor and against Defendant, Giant Food Stores, LLC, for compensatory damages in an amount in excess of FIFTY THOUSAND 8v 00/ 100 ($50,000.00) DOLLARS, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully Submitted, FREEBURN & HAMILTON By: C Christina L. Bradley, Es ire I.D. No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671-1955 Date: ~~~~~~~ ~ 13 Counsel for Plaintiffs VERIFICATION I, Eugene Motes, hereby verify that the statements in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: i I ~ 1 Eugene Motes VERIFICATION I, Tricia Motes, hereby verify that the statements in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: J I ~~ ~'~ ~`^~M1-~~J/ Tricia Motes VERIFICATION I, Courtney Motes, hereby verify that the statements in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ~-~-~v~ Courtney Motes CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA , PURSUANT TO RULE 4009.22 �` J(J1' AL IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things p� ualit�` .-, to Rule 4009.22 t'- -n. =mr :>> 7::cD c7 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS o r-/-l f`.f DATE: 10/07/2013 ��,,�y 1 I GEORGE B. F' Ab R, JR. , ES7 Attorney for DEFENDANT MCS # 36912-L01 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES -VS- CASE NO: 13-250 GIANT FOOD STORES NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009 .21 CAMP HILL FAMILY CARE MEDICAL RECORDS & BILLING HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL BILLING ONLY TO: CHRISTINA L. BRADLEY, ESQ. , PLAINTIFF COUNSEL MCS on behalf of GEORGE B. FALLER, JR. , 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. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/13/2013 MCS on behalf of GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT CC: GEORGE B. FALLER, JR. , ESQ. - 9500.622 THE MCS GROUP INC. CHRISTINA L. BRADLEY, ESQ. 1601 MARKET STREET FREEBURN & HAMILTON #800 2040 LINGLESTOWN ROAD PHILADELPHIA, PA 19103 SUITE 300 (215) 246-0900 HARRISBURG, PA 17110 MCS # 36912-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • COURTNEY MOTES,EUGENE MOTES &TRICIA : MOTES File No. 13-250 • vs. • GIANT FOOD STORES • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CAMP HILL FAMILY CARE (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: GEORGE B.FALLER, JR.,ESQ. ADDRESS: 10 E.HIGH STREET CARLISLE.PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: I i . ! i, Prothonotary/Clerk,Civil Division q//0/8 3 Deputy Date: Seal of the Court 36912-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CAMP- HILL FAMILY CARE 4400 CARLISLE PIKE CAMP HILL, PA 17011 RE: MCS # 36912-L01 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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 $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-LOl SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS o b-half if DATE: 10/07/2013 ./# i GEORGE :ALLER, JR. , ESS' Attorney for DEFENDANT MCS # 36912-L02 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • COURTNEY MOTES,EUGENE MOTES&TRICIA : MOTES File No. 13-250 vs. • • GIANT FOOD STORES • 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: GEORGE B. FALLER.JR.. ESQ. ADDRESS: 10 E. HIGH STREET CARLISLE. PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: rgUe--66-- e Prothonotary/Clerk,Civil Division (9/0 /! Deputy Date: Seal of the Court 36912-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: MCS # 36912-L02 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: 162-76-3759 Date of Birth: 10-12-1994 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. 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 $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L02 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS o •- , al f of DATE: 10/07/2013 , /44 r2; GEOR=E B. A LER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-L03 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • COURTNEY MO TES,EUGENE MOTES&TRICIA : MOTES File No. 13-250 vs. • GIANT FOOD STORES • • • 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: GEORGE B. FALLER.JR.. ESQ. ADDRESS: 10 E. HIGH STREET CARLISLE,PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division 4.... /al:Zit...L..4C?eVa2/24,14c Deputy Date: 9/0/2 Seal of the Court 36912-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL BILLING DEPARTMENT 111 S. FRONT STREET HARRISBURG. PA 17105 RE: MCS # 36912-L03 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: 162-76-3759 Date of Birth: 10-12-1994 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 $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L03 SU10 A CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGINAL IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES c?g As a prerequisite to service of a subpoena for documents and things uds+t ---f to Rule 4009.22 O P t t"w +;r is CD MCS on behalf of GEORGE B. FALLER, JR. , ESQ. I*Cz 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. 110 on b alf of DATE: 10/23/2013 GEORGE B. F L ER, JR. , ESQ. Attorney fcfr nEFENDANT MCS # 36912-L04 DE11 . .s COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES -VS- CASE NO: 13-250 GIANT FOOD STORES NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009 .21 PA BUREAU OF DISABILITY DETER. RECORDS TO: CHRISTINA L. BRADLEY, ESQ. , PLAINTIFF COUNSEL MCS on behalf of GEORGE B. FALLER, JR. , 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. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/01/2013 MCS on behalf of GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT CC: GEORGE B. FALLER, JR. , ESQ. - 9500.622 THE MCS GROUP INC. CHRISTINA L. BRADLEY, ESQ. 1601 MARKET STREET FREEBURN & HAMILTON #800 2040 LINGLESTOWN ROAD PHILADELPHIA, PA 19103 SUITE 300 (215) 246-0900 HARRISBURG, PA 17110 MCS # 36912-001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES, EUGENE MOTES&TRICIA File No. 13-250 vs. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PA BUREAU OF DISABILITY DETER. (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: GEORGE B. FALLER, JR.,ESQ. ADDRESS: 10 E. HIGH STREET CARLISLE, PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: ' - -S.,,ZL OCT 2 3 2013 Prothonotary/Clerk, Civil Division (n Deputy C, LWFCe Date: � ��`'` Seal of the Court 36912-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PA BUREAU OF DISABILITY DETER. 1171 S. CAMERON STREET ROOM 109 HARRISBURG, PA 171042594 RE: MCS # 36912-L04 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: 162-76-3759 Date of Birth: 10-12-1994 ANY & ALL RECORDS AVAILABLE Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L04 SU10 ` CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES C. -v As a prerequisite to service of a subpoena for documents and thingsiFr7uaLt to Rule 4009.22 ==1 - MCS on behalf of GEORGE B. FALLER, JR. , ESQ. y C7- 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. MC b DATE: 01/13/2014 GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-,L05 DE11 t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES -VS- CASE NO: 13-250 GIANT FOOD STORES NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ORTHOPAEDIC INSTITUTE OF PA MEDICAL RECORDS & BILLING DRAYER PHYSICAL THERAPY INSTIT MEDICAL RECORDS & BILLING DIAKON FAMILY LIFE SERVICES MEDICAL RECORDS & BILLING BEHAVIROAL HEALTH CENTER MEDICAL RECORDS & BILLING CPRS PHYSICAL THERAPY MEDICAL RECORDS & BILLING CAMP HILL FAMILY CARE MEDICAL RECORDS & BILLING TRISTAN ASSOCIATES MEDICAL RECORDS & BILLING TO: CHRISTINA L. BRADLEY, ESQ. , PLAINTIFF COUNSEL MCS on behalf of GEORGE B. FALLER, JR. , 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. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2013 MCS on behalf of GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT CC: GEORGE B. FALLER, JR. , ESQ. - 9500.622 THE MCS GROUP INC. CHRISTINA L. BRADLEY, ESQ. 1601 MARKET STREET FREEBURN & HAMILTON #800 2040 LINGLESTOWN ROAD PHILADELPHIA, PA 19103 SUITE 300 (215) 246-0900 HARRISBURG, PA 17110 MCS # 36912-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES,EUGENE MOTES&TRICIAMOTES File No. 13-250 VS. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPAEDIC 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**** at The MCS Group.Inc., 1601 Market Street,Suite 800,P ila&whia,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: GEORGE B.FALLER_JR.,ESQ. ADDRESS: 10 E.HIGH STREET CARLISLE,PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: 7 I Prothonotary/Clerk,Civil Division JAN 1 3 2014 Deputy Date: p( Seal of the Court 36912-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC INSTITUTE OF PA 3399 TRINDLE ROAD 2ND FLOOR CAMP HILL, PA 17011 RE: MCS # 36912-L05 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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$150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L05 SU10 + CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS on behalf of DATE: 01/13/2014 GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-L06 DE11 ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES,EUGENE MOTES&TRICIAMOTES File No. 13-250 VS. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DRAYER PHYSICAL THERAPY INSTIT (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.PhiladelphijL 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: GEORGE B.FALLER JR.,ESQ. ADDRESS: 10 E HIGH STREET C ARUSLE,PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: jum, 1AA Prothonotary/Clerk,Civil Division 1,14 3 Deputy Date: Seal of the Court 36912-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DRAYER PHYSICAL THERAPY INSTIT 8205 PRESIDENTS DRIVE FIRST FLOOR HUMMELSTOWN, PA 17036 RE: MCS # 36912-L06 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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 $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L06 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS on behalf of DATE: 01/13/2014 GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES,EUGENE MOTES&TRICIAMOTES File No. 13-250 VS. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DLAKON FAMILY LIKE 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 Stre"Suite 800,Ph11adelplia,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: GEORGE B.FALLER.JR..ESQ. ADDRESS: 10 E.HIGH STREET CARLISLE,PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division -- J 2014 Deputy Date: Seal of the Court 36912-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DIAKON FAMILY LIFE SERVICES 960 CENTURY DRIVE MECHANICSBURG, PA 17055 RE: MCS # 36912-L07 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments .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 $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-,L07 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS on behalf of DATE: 01/13/2014 GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-L08 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES,EUGENE MOTES&TRICIAMOTES File No. 13-250 VS. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BEHAVIROAL HEALTH CENTER (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 Cg= 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: GEORGE B.FALLER.JR..ESQ. ADDRESS: 10 E.HIGH STREET CARLISLE,PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant IBY THE COURT: Yli 1� Prothonotary/Clerk,Civil Division 1 2 4 Deputy Date: Seal of the Court 36912-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BEHAVIROAL HEALTH CENTER 503 N 21ST. STREET CAMP HILL, PA 17011 RE: MCS # 36912-L08 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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 qeq ui red for fees in excess of$150.00 for hospitals, $100.00 or all other providers. MCS # 36912-LO8 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS on behalf of DATE: 01/13/2014 GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-L09 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES,EUGENE MOTES&TRICIAMOTES File No. 13-250 VS. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CPRS PHYSICAL THERAPY (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 Q=,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: GEORGE B.FALLER.JR.,ESQ. ADDRESS: 10 E.HIGH STREET CARLISLE,PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: _Defendant BY THE COURT: Prothonotary/Clerk,Civil Division - I NI P 2014 / f Deputy Date: Seal of the Court 36912-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CPRS PHYSICAL THERAPY 3916 TRINDLE ROAD CAMP HILL, PA 17011 RE: MCS # 36912-LO9 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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$150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L09 SU10 • CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS on behalf of DATE: 01/13/2014 GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-LlO DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES,EUGENE MOTES&TRICIAMOTES File No. 13-250 VS. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CAMP HILL FAMILY CARE (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: GEORGE B FALLER JR..ESQ. ADDRESS: 10 E. HIGH STREET CARLISLE.PA 17013 TELEPHONE:0)746-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division J� �. � 14 uty /� /� Dep Date: Seal of the Court 36912-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CAMP HILL FAMILY CARE 4400 CARLISLE PIKE CAMP HILL, PA 17011 RE: MCS # 36912-L10 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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$150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L10 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -vs- CASE NO: 13-250 GIANT FOOD STORES As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR. , 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. MCS on behalf of DATE: 01/13/2014 GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT MCS # 36912-L11 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES,EUGENE MOTES&TRICIAMOTES File No. 13-250 VS. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for TRIST N ASSOCIATES (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: GEORGE B.FALLER JR..ESO. ADDRESS: 10 E.HIGH STREET CARLISLE,PA 17013 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: 1 Prothonotary/Clerk,Civil Division JANl 20 Dep /� 10 ,?uty Date: Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TRISTAN ASSOCIATES 240 GRANDVIEW AVE. CAMP HILL, PA 17011 RE: MCS # 36912-Lll COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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$150.00 for hospitals, $100.00 for all other providers. MCS # 36912-Lll SU10 4. CERTIFICATE �y PREREQUISITE TO SERVICE OF A SUBPOENA ORIGINAL PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES CUMBERLAND -VS- CASE NO: 13-250 GIANT FOOD STORES f-- - P p g P As a prerequisite to service of a subpoena for documents and things a , �'ry`: to Rule 4009.22 :2 - C, =c) _. MCS on behalf of GEORGE B. FALLER, JR. , 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. MCar4� 'f of DATE: 02/03/2014 GEORGE B. F'.LER, JR. , ESQ. Attorney fo: DEFENDANT MCS # 36912-L12 DE11 -.0i -4. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA TERM, MOTES -VS- CASE NO: 13-250 GIANT FOOD STORES NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 KLINE FAMILY PRACTICE MEDICAL RECORDS & BILLING TO: CHRISTINA L. BRADLEY, ESQ. , PLAINTIFF COUNSEL MCS on behalf of GEORGE B. FALLER, JR. , 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. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/10/2014 MCS on behalf of GEORGE B. FALLER, JR. , ESQ. Attorney for DEFENDANT CC: GEORGE B. FALLER, JR. , ESQ. - 9500.622 THE MCS GROUP INC. CHRISTINA L. BRADLEY, ESQ. 1601 MARKET STREET FREEBURN & HAMILTON #800 2040 LINGLESTOWN ROAD PHILADELPHIA, PA 19103 SUITE 300 (215) 246-0900 HARRISBURG, PA 17110 MCS # 36912-CO1 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND • • COURTNEY MOTES,EUGENE MOTES &TRICIAMOTES • • File No. 13-250 vs. • GIANT FOOD STORES • • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for KLINE FAMILY PRACTICE (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: GEORGE B.FALLER,JR.,ESQ. ADDRESS: 10 E.HIGH STREET CARLISLE,PA 17013 TELEPHONE: (215)24 -0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk,Civil Division Deputy Date: Seal of the Court 36912-12 NIMINIIIIIIMMIl EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KLINE FAMILY PRACTICE 2601 N.3RD STREET HARRISBURG, PA 17110 RE: MCS # 36912-L12 COURTNEY MOTES 279 SUSQUEHANNA AVENUE ENOLA, PA 17025 • Social Security #: XXX-XX-3759 Date of Birth: 10-12-1994 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 but not limited to, itemized billing, insurance claims, invoices and payments 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$150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L12 Su10 22V; 07i 20 Ft 1' COUTY 11 '77 L..r.SPt IN THE MATTER OF: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA:' PURSUANT TO RULE 4009.22 COURTNEY MOTES, EUGENE MOTES & TRICIA MOTES GIANT FOOD STORES COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- CASE NO: 13-250 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR., 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: 10/03/2014 MCS GEO• B. FAAF, Attorney for DEFE 4 , ESQ. T MCS # 36912-L13 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURTNEY MOTES, EUGENE MOTES & TRICIA MOTES -VS- GIANT FOOD STORES COURT OF COMMON PLEAS TERM, CASE NO: 13-250 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CITIZENS HOSE COMPANY EMS RECORDS GRANDVIEW SURGERY CENTER MEDICAL RECORDS TO: CHRISTINA L. BRADLEY, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE B. FALLER, JR., 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: 09/11/2014 CC: GEORGE B. FALLER, JR., ESQ. - 9500.622 CHRISTINA L. BRADLEY, ESQ. FREEBURN & HAMILTON 2040 LINGLESTOWN ROAD SUITE 300 HARRISBURG, PA 17110 MCS on behalf of GEORGE B. FALLER, JR., ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 36912-001 DE02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES, EUGENE MOTES & TRICIAMOTES File No. 13-250 vs. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CITIZENS HOSE COMPANY (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: GEORGE B. FALLER, JR., ESQ. ADDRESS: 10 E. HIGH STREET CARLISLE, PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: OCT 0 3 2014 alghy Seal of the Court BY THE COURT: Protionotaryterk, CiviDivision Deputy 36912-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CITIZENS HOSE COMPANY 4807 JONESTOWN ROAD SUITE 247 HARRIBURG, PA 17107 RE: MCS # 36912-L13 COURTNEY MOTES AKA COURTNEY HEFFELFINGER, 279 SUSQUEHANNA AVE ENOLA, PA 17025 Social Security #: XXX -XX -3759 Date of Birth: 10-12-1994 Please provide all treatment, transport, and any refusal of treatment records . This should contain all records in your possession, all archived records and records in storage. Include any items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L13 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS COURTNEY MOTES, EUGENE MOTES & TRICIA MOTES GIANT FOOD STORES TERM, CUMBERLAND -VS- CASE NO: 13-250 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE B. FALLER, JR., 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: 10/03/2014 MCS on behalf of GEORGE B. FALLER, JR., ESQ. Attorney for DEFENDANT MCS # 36912-L14 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURTNEY MOTES, EUGENE MOTES & TRICIAMOTES File No. 13-250 vs. GIANT FOOD STORES SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for GRANDVIEW SURGERY CENTER (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: GEORGE B. FALLER, JR., ESQ. ADDRESS: 10 E. HIGH STREET CARLISLE, PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: = OCT 0 3 2014 cile/Y. Seal of the Court BY T C • RT: Prothonotary/Clerk, ' ivil Division Deputy 36912-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GRANDVIEW SURGERY CENTER 205 GRANDVIEW AVENUE SUITE 101 CAMP HILL, PA 17011 RE: MCS # 36912-L14 COURTNEY MOTES AKA COURTNEY HEFFELFINGER, 279 SUSQUEHANNA AVE ENOLA, PA 17025 Social Security #: XXX -XX -3759 Date of Birth: 10-12-1994 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 $150.00 for hospitals, $100.00 for all other providers. MCS # 36912-L14 SU10