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HomeMy WebLinkAbout02-0736HUNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs J. CRAIG JURGENSEN, M.D. Belevedre Medical Cemer 850 Walnut Bottom Road Carlisle, PA 17013 CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL 246 Parker Street Carlisle, PA 17013-0310 Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CWIL ACTION - LAW NO. ag' V-St0 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()Attomey~ S~~ Neil J. Rovner, Esquire 4503 North Front Street Signature of,~tl~nev / Harrisburg, PA 17110 717/238-6791 I.D. No. 22108 Date:~ WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED COMMENCED AN ACTION AGAINST YOU. Pro~ Date:~_.~ Ili ~.~_C)O_~__~ 242427. I hNJRhMAR PLAINTIFF(S) HAS/HAVE MICHAEL M. BADOWSKI, ESQUIRE Pa. Supreme Court I.D. No. 32646 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone= Fax= E-Mail= [717] 975-8114 [717] 975-8124 mbadowski~margolisedelstein.com Attorney for Defendant, J. Craig Jurgensen, M.D. HUNTER GRIFFIE, A MINOR, by S~LANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, PLAINTIFF, VS. J. CRAIG JURGENSEN, M.D. AND CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL, DEFENDANTS. : IN THE COURT OF COMMON PLEAS :CUMBERLA/qD COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 02-736 JURY TRIAL DEb~NDED PRAECIPE TO ENTER APPEARANC~ TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Kindly enter my appearance on behalf of Defendant, CRAIG JURGENSEN, M.D., Date: in the above-captioned matter. M~CHAEL M /BA~DOWSKI Attorney for Defendant, J. CRAIG JURGENSEN, M.D. CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the C~day of.~O' 2002, and addressed as follows: ~ Neil J. Rovner, Esquire ANGINO & ROVNER 4503 North Front Street Harrisburg, PA 17110 (Attorney for Plaintiffs) Carlisle Regional Medical Center, Successor to Carlisle Hospital 246 Parker Street Carlisle, PA 17013-0319 MARGOLI S EDELSTEIN By: Paraleg~ MIC~L M. BADOWSKI, ESQUIP, E Pa. Supreme Court I.D. No. 32646 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone: [717] 975-8114 Fax: [717] 978-8124 E-~hail: ~flDadowski@margolisedelstein.com Attorney for Defendant, J. Craig Jurgensen, M.D. HUNTER GRIFFIE, A MINOR, by S~ANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, PLAINTIFF, VS. J. CRAIG JURGENSEN, M.D. AND CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL, DEFENDANTS. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 02-736 JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue Rule upon Plaintiffs to file twenty Date: a Complaint within (20) days from service hereof or su~fer judgment non pros. R'ICHAEL~M',z~BADOWSKI Attorney for Defendant, J. CRAIG JURGENSEN, M.D. RULE TO THE PLAINTIFF: You are hereby ordered and directed to file your Complaint against the Defendant in the above-captioned matter within twenty (20) days of service of this Rule against you or suffer judgment non pros. Dated:~ ~' ~. ~ ~ Prothono~ SHERIFF'S RETURN - REGULAR CASE NO: 2002-00736 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRIFFIE HUNTER ET AL VS JURGENSEN J CRAIG MD ET AL HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon CARLISLE REGIONAL MEDICAL CENTER the DEFENDANT , at 1607:00 HOURS, on the 20th day of February , 2002 at 246 PARKER STREET CARLISLE, PA 17013-0310 MA~INE BARRICK, by handing to HUMAN RESOURCES a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 19.45 Sworn and Subscribed to before me this ~7~Q day of ~~, ~,~ A.D. [/ Prat ~onot ar~// So Answers: R. Thomas Kline 02/21/2002 ANGINO & ROVNER SHERIFF'S RETURN - REGULAR CASE NO: 2002-00736 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRIFFIE HUNTER ET AL VS JURGENSEN J CRAIG MD ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon JURGENSEN J CRAIG MD the DEFENDANT at BELEVEDRE MEDICAL CENTER CARLISLE, PA 17013 DEBORAH FABRIZIO, a true and attested copy of WRIT OF SUMMONS , at 1505:00 HOURS, on the 15th day of February , 2002 850 WALNUT BOTTOM ROAD by handing to MEDICAL SECRETARY together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this ~7~ day of ~o~h~notaryU So Answers: R. Thomas Kline 02/21/2002 ANGINO & ROVNER Deputy Sh~iff MIC}L~EL M. BADOWSKI, ESQUIRE Pa. Supreme Court I.D. No. 32646 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone: Fax: E-Mail: [717] 975-8114 [717] 975-8124 mbadowski~margolisedelstein.com Attorney for Defendant, J. Craig Jurgensen, M.D. HUNTER GRIFFIE, A MINOR, by SHANNON GRIFFIE and PJ~NDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, PLAINTIFF, VS. J. CRAIG JURGENSEN, M.D. AND CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL, DEFENDANTS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 02-736 JURY TRIAL DEMANDED P RA E C I P E TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Kindly file of record the attached Certificate of Service of the Rule which was entered by you on February 27, 2002, and served on the date reflected in the attached Certificate of Service. Date: Attorney for Defendant, J. CRAIG JURGENSEN, M.D. MICHAEL M. BADOWSKI, ESQUIRE Pa. Supreme Cour= I.D. No. 32646 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone: Fax: E-Mail: [717] 975-8114 [717] 975-8124 mbadowski@margolisedelstein.com Attorney for Defendant, J. Craig Jurgensen, M.D. HUNTER GRIFFIE, A MINOR, by S~ANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, PLAINTIFF, VS. J. CRAIG JURGENSEN, M.D. AND CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL, DEFENDANTS. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 02-736 JURY TRIAL DEMANDED PR~tECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue Rule upon Plaintiffs to file a Complaint within twenty Date: (20) days from service hereof or su~ ~ICHAEL Attorney J. CRAIG ~er judgment non pros. ADOWSKI for Defendant, JURGENSEN, M.D. RULE TO THE PLAINTIFF: You are hereby ordered and directed to file your Complaint against the Defendant in the above-captioned matter within twenty {20) days of service of this Rule against you or suffer judgment non pros. Da~ed: ~/~/ ~z.D~k~ ~ T~E ~PY FROM REaR I~ ~y ~r~f, I ~re un~ CERTIFICATE OF SERVICE the the Prothonotary of Dauphin County on November 8, 2001, parties of record or their counsel by placing the same United States mail at Camp Hill, Pennsylvania, postage prepaid, on the 4th day of March, 2002, follows: I HEREBY CERTIFY that I served a true and correct copy of Rule to File Complaint entered in the foregoing action, by Neil J. Rovner, Esquire ANGINO & ROVNER 4503 North Front Street Harrisburg, PA 17110 (Attorney for Plaintiffs) upon all in the first-class and addressed as Carlisle Regional Medical Center, Successor to Carlisle Hospital 246 Parker Street Carlisle, PA 17013-0319 MARGOLIS EDELSTEIN CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the ~ day of ~ ~ ~ , 2002, and addressed as follows: Neil J. Rovner, Esquire ANGINO & ROVNER 4503 North Front Street Harrisburg, PA 17110 (Attorney for Plaintiffs) Carlisle Regional Medical Center, Successor to Carlisle Hospital 246 Parker Street Carlisle, PA 17013-0319 MARGOLIS EDELSTEIN HUNTER GRIFFIE, a minor, by SHANNON GRIFFIE and RANDY GRIFFIE, his parents and natural guardians and SHANNON GRIFFIE and RANDY GRIFFIE, individually and in their own right, Plaintiffs J. CRAIG JURGENSEN, M.D., and CARLISLE REGIONAL MEDICAL CENTER, successor to CARLISLE HOSPITAL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. DOCKET NO. 02-736 Civil CIVIL ACTION - LAW JURY TRIAL DEMAND ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for Defendant, Carlisle Health and Wellness Foundation formerly Carlisle Hospital and Health Services (erroneously styled "Carlisle Regional Medical Center, successor to Carlisle Hospital"), in the above-captioned matter. Respectfully submitted, FARRELL & RICCI, P.C. Date: Attorney I.D. No. 68921 4423 North Front Street Harrisburg, PA 17110 (717) 230-9201 Counsel for Defendant Carlisle Health and Wellness Foundation CERTIFICATE OF SERVICE AND NOW, this ~ day of March, 2002, I, Joseph A. Ricci, Esquire, hereby certify that I served a true and correct copy of the foregoing Entry of Appearance upon all counsel of record by depositing a copy of same in the United States mail, regular delivery, postage prepaid at Harrisburg, Pennsylvania, addressed as follows: Neff J. Rovner, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Michael M. Badowski, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 oseP~icci, Esquire HUNTER GRIFFIE, a minor, by SHANNON GRIFFIE and RANDY GRIFFIE, his parents and natural guardians and SHANNON GRIFFIE and RANDY GRIFFIE, individually and in their own right, Plaintiffs J. CRAIG JURGENSEN, M.D., and CARLISLE REGIONAL MEDICAL CENTER, successor to CARLISLE HOSPITAL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. DOCKET NO. 02-736 Civil CIVIL ACTION - LAW JURY TRIAL DEMAND PRAECIPE FOR RULE TO FILE A COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule upon Plaintiffs to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, FARRELL & RICCI, P.C. Date: March ~ ,2002 (~oseph A. ~i~ci, Esquire ~torney I.D. ~o. 49803 L a'W~e,~c_e F.,~arone Attorney I.D. No. 68921 4423 North Front Street Harrisburg, PA 17110 (717) 230-9201 Counsel for Defendant Carhsle Health and Wellness Foundation HUNTER GRIFFIE, a minor, by SHANNON GRIFFIE and RANDY GRIFFIE, his parents and natural guardians and SHANNON GRIFFIE and RANDY GRIFFIE, individually and in their own right, Plaintiffs J. CRAIG JURGENSEN, M.D., and CARLISLE REGIONAL MEDICAL CENTER, successor to CARLISLE HOSPITAL, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. DOCKET NO. 02-736 Civil CIVIL ACTION - LAW JURY TRIAL DEMAND RULE TO FILE A COMPLAINT TO: Hunter Grfffie, a minor, by Shannon Griffie and Randy Griffie, his parents, Plaintiffs c/o Neff J. Rovner, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Counsel for Plaintiffs You are hereby ruled to file a Complaint within twenty (20) days of receipt of this Rule or suffer a judgment of non pros. Dated:~,~X ' Pro~hon-ot~ CERTIFICATE OF SERVICE AND NOW, this ~ ~ day of March, 2002, I, Joseph A. Ricci, Esquire, hereby certify that I served a true and correct copy of the foregoing Praecipe for Rule to File a Complaint upon all counsel of record by depositing a copy of same in the United States mail, regular delivery, postage prepaid at Harrisburg, Pennsylvania, addressed as follows: Neil J. Rovner, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Michael M. Badowski, Esquire Margohs Edelstein P.O. Box 932 Harrisburg, PA 17108-0932 HUNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs J. CRAIG JURGENSEN, M.D., CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 02-736 JURY TRIAL DEMANDED STIPULATION FOR CHANGE OF CAPTION AND SUBSTITUTION OF PARTIES 1. On February 11, 2002, Plaintiff filed a Writ of Summons against Carlisle Regional Medical Center, Successor to Carlisle Hospital. 2. Plaintiffs have been informed that at the time in question the official name of the corporation was Carlisle Hospital and Health Services. 3. Carhsle Hospital and Health Services is a predecessor of the current Carlisle Health and Wellness Foundation. 4. Plaintiffs therefore wish to substitute Carlisle Health and Wellness Foundation as Successor to Carlisle Hospital and Health Services for Carlisle Hospital in the above captioned action. 5. Plaintiff has secured the agreement of counsel for Carlisle Health and Wellness Foundation for the substitution by Stipulation. 243377.1hNJR~MAR 6. Accordingly, Plaintiffs seek to amend the caption to read as follows: HUNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE, INDWIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs J. CRAIG JURGENSEN, M.D., CARLISLE HEALTH AND WELLNESS FOUNDATION, SUCCESSOR TO CARLISLE HOSPITAL AND HEALTH SERVICES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 02-736 JURY TRIAL DEMANDED Respectfully submitted, ANGINO & RO , · 4503 N. Front ~treet Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff(s) Date: ~)~ lc~ Respect fu~fibm~t_e~,_ _ _ ~vl~fhaef 1~I.' l~dowski, Esquire I.D. No. 32646 3510 Trindle Road Camp Hill, PA 17011 (717) 975-8114 Counsel for Defendant Jurgensen, M.D. Date: ~ / 2 IC~ Respectfully submitted, FARRELL & RICCI J~h A. R)~ci, Esquire ~423 North~tront Street l:tan:i~sb~, PA 1711O Date: ~/z 1 6'2. 243377. lhNJR~MAR CERTIFICATE OF SERVICE I, Megan A. Reinard, an employee of the law finn of Angino & Rovner, P.C., do hereby certify that I am this day serving a tree and correct copy of the foregoing upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael Badowski, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17011 Counsel for J. Craig Jurgensen, M.D. Joseph A. Ricci, Esquire Farrell & Ricci, P.C. 4423 North Front Street Harrisburg, PA 17110 Counsel for Carlisle Health And Wellness Foundation, Successor To Carlisle Hospital And Health Services Megan ~. Reinard Dated: L~ I,~q~ 244549.1~qJRkMAR APR 0 HUNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE. INDIVIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs J. CRAIG JURGENSEN, M.D., CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 02-736 JURY TRIAL DEMANDED AND NOW, thiS ORDER ,( dayof ~..J .2002, uponconsiderafionof the attached Stipulation of Counsel, it is hereby ORDERED that caption be amended as follows: HUNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs J. CRAIG JURGENSEN, M.D., CARLISLE HEALTH AND WELLNESS FOUNDATION, SUCCESSOR TO CARLISLE HOSPITAL AND IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 02-736 JURY TRIAL DEMANDED HLrNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs $. CRAIG JURGENSEN, M.D., CARLISLE REGIONAL MEDICAL CENTER, SUCCESSOR TO CARLISLE HOSPITAL Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 02-736 JURY TRIAL DEMANDED STIPULATION FOR CHANGE OF CAPTION AND SUBSTITUTION OF PARTIES 1. On February 11, 2002, Plaintiff filed a Writ of Summons against Carlisle Regional Medical Center, Successor to Carlisle Hospital. 2. Plaintiffs have been informed that at the time in question the official name of the corporation was Carlisle Hospital and Health Services. 3. Carlisle Hospital and Health Services is a predecessor of the current Carlisle Health and Wellness Foundation. 4. Plaintiffs therefore wish to substitute Carlisle Health and Wellness Foundation as Successor to Carlisle Hospital and Health Services for Carlisle Hospital in the above captioned action. 5. Plaintiff has secured the agreement of counsel for Carlisle Health and Wellness Foundation for the substitution by Stipulation. 243377.1XNJRWiAR 6. Accordingly, Plaintiffs seek to amend the caption to read as follows: HUNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs J. CRAIG JURGENSEN, M.D., CARLISLE HEALTH AND WELLNESS FOUNDATION, SUCCESSOR TO CARLISLE HOSPITAL AND HEALTH SERVICES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 02-736 JURY TRIAL DEMANDED Respectfully submitted, I.D. No. ~24~08 / 4503 N. Front ~treet Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff(s) Date: ~ }~ lC~2 Respectfull ~fi~fibmitted, M7~/~/O'~ l[dl~haef 1~ l~dowski, Esquire I.D. No. 32646 3510 Tfindle Road Crop Hill, PA 17011 (717) 975-8114 Co~sel for Defend~t Jurgensen, M.D. Date: ~ ~ 2 ~7 Respectfully submitted, FARRELL & RICCI h A. PdX~Ci, Esquire ont Street Ylat:lS~, PA 17110 Date: ~.,/z IO2. 243377.1~NJR~vIAR CERTIFICATE OF SERVICE I, Megan A. Reinard, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the foregoing upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael Badowski, Esquire Margolis Edelstein P.O. Box 932 Harrisburg, PA 17011 Counsel for J. Craig Jurgensen, M.D. Joseph A. Ricci, Esquire Farrell & Ricci, P.C. 4423 North Front Street Harrisburg, PA 17110 Counsel for Carlisle Health And Wellness Foundation, Successor To Carlisle Hospital And Health Services Megan ~. Reinard Dated: 244549.1XNJRWiAR HUNTER GRIFFIE, A MINOR, BY SHANNON GRIFFIE AND RANDY GRIFFIE, HIS PARENTS AND NATURAL GUARDIANS AND SHANNON GRIFFIE AND RANDY GRIFFIE, INDIVIDUALLY AND IN THEIR OWN RIGHT, Plaintiffs Vo J. CRAIG JURGENSEN, M.D., CARLISLE HEALTH AND WELLNESS FOUNDATION, SUCCESSOR TO CARLISLE HOSPITAL AND HEALTH SERVICES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 02-736 JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Please mark the above captioned matter discontinued without prejudice. Respectfully submitted, ANGINO & ROVNER, P.C. Harrisburg, P/A 17110 (717) 238-6791 Counsel for Plaintiff(s) 245588.1 kNJRhMAR CERTIFICATE OF SERVICE I, Megan A. Reinard, an employee of the law firm of Ang/no & Rovner, P.C., do hereby certify that I am this day serving a tree and correct copy of the foregoing upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael Badowski, Esquire Margolis Edelstein ?.O. Box 932 Harrisburg, PA 17011 Counsel for J. Craig Jurgensen, M.D. Joseph A. Ricci, Esquire Farrell & Ricci, P.C. 4423 North Front Street Harrisburg, PA 17110 Counsel for Carlisle Health and Wellness Foundation '7t &. ce/ Megat~A. Reinard 245588.1 ~NSR~,IAR CEI~TIFIC, ATE PP-EKEQ~ISITE TO SEI~%'ICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: HUNTER MATHEW GRIFFIE COURT OF COMMON PLEAS TERM, -VS- JURGENSEN, ET AL CASE NO: 02-736 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL BADOWSKI~ ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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: 0510612002 MICHAEL BADOWSKI~ EsquIRE Attorney for DEFENDANT DEll-330728 90392--L01 COIqlVIOI~TT~e:Ar-TH OF PENNS~fI.V.%/qIA COUlqTY OF CT31HREI~T-~%IqD IN THE MATTEl{ OF: HUNTER MAx~u~W GEIFFIE -VS- JuKGENSEN, ET AL COURT OF CO~40N PLEAS TERM, CASE NO: 02-736 NOTICE OF Il~El~ ~0 SERVE A SUBPOENA TO PRODUCE DOCTm~S · HINGS FOR DISCOVERY PURSUANT TO RULE 4009.2] MILTON ~S~ ~ICAL CENTER M~.nICAL RECORDS CARLISLE PEDIATRIC ASSOC ~oICAL RECORDS TO: JOSEPH A. EICCI, ESQ. NEIL ROV~za, ESQUIRE HCS on behalf of MICNA~. B~DO~S~, ESqUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twnty (20) days from the date listed below in ~hich 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 s.m- to MCS or by contacting our local HCS office. DATE: 04/1612002 CC: MICHAEL BADO~SKI, ESQUIRE DAUUYL SCHLAPPICH - 57300-4-00134 - 33800001 Any questions regarding this matter, contact NCS on behalf of MICNA~. BADO~SI[, ESqUIRE Attorney for DE~mqDA[~ Ttt~I4CS GROUP INC. 1601 14ARB~T SI~R~.T ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-184424 90392--C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HUNTER MATHEW GRIFFIE VS JURGENSEN, ET AL File No.02-736 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.2? TO: CUSTODIAN OF RECORDS FOR: MILTON HERSHEY MEDICAL 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 ATTACI~..t~ at THE MCS GROUP INC., 1601 MARKET STREET, #800, PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL BADOWSKI, ESQUIRE ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215)246-0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFENDANT DATE: Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE PO BOX 850 HERSHEY, PA 17033 RE: 90392 HUNTER MATHEW GRIFFIE Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates ~e. quested: up to and including the present. Subject .HUNTER MATHEW GRIFFIE 190 PINE SCHOOL ROAD, GARDNERS, PA 17324 Date of Birth: 08-08-1997 SU10-368532 90392--L01 P~,EREQUI$ITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: HUNTER MATHEW GRIFFIE COURT OF COMMON PLEAS TERM, -VS- JURGENSEN, ET AL CASE NO: 02-736 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL BADOWSKI, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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: 05/06/2002 MCS on behalf of MICHAEL BADOWSKI, ESQUIRE Attorney for DEFENDANT DEll-330729 9 0 3 92--L02 COI~I~IOI~rJZALTH OF PENNS~fI~VANIA COI31~TY OF CUi~IBERLAND IN THE MATTER OF: HUNTER MATHEWGRIFFIE -VS- JURGENSEN, ET AL COURT OF COati, ON PLEAS TERM, CASE NO: 02-736 NO~ICE OF INTEI~ TO SERVE A SUBPOENA TO PRODUCE DOCtoR.S ~ FOR DISCOV~.~ PURSUAN~ TO RULE 4009.2] HILTON HERStJ~Y HEDICAL CENTER ~.0IC&L RECORDS CARLISLE PEDIATRIC ASS0C M~q~ICAL RECORDS TO: NEIL HOVNza, ESQUIRE JOSEPH A. HICCI, ESQ. HCS on behalf of HICHAEL BADOI~SE/~ ESqUIRE 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 ~ade, then the subpoena ~-y be served. C~lete copies of any reproduced records ~-y be ordered at your expense by c~m~leting the attached counsel card and returning s--~ to HCS or by contacting our local MCS office. DATE: 04/16/2002 CC: HICWAm. BADO~SKI, ESQUIRE DAR~YL SCm~PPICH - 57300-4-00134 - 33800001 Any questions regarding this matter, contact HCS on behalf of HICIL~. BADOI~SKI, ESqUIRE Attorney for DEFENDANT THE H CS GROUP INC. 1601 HARKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-184423 90392--C03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GRIFFIE : : VS : : 3URGENSEN, ET AL : : : File No. 02-736 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009_?7 TO: CUSTODIAN OF RECORDS FOR:CARLISLE PEDIATRIC ASSOC. (Name of Person or Entity) Within twenty (20) days after service of this su ~en~o/~G0~rdered by the court to produce the following documents or things: at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 -- (Addre~) 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: MICHAEL BADOWSKI. ESQ, ADDRESS: 3510 TRINDLE RD. CAMP HILL. PA 1701~ TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court Prothonotary/Clerk, Civil~q~on (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE PEDIATRIC ASSOC 804 BELVEDERE STREET CARLISLE, PA 17110 RE: 90392 HUNTER MATHEW GRIFFIE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: upto and includinl~ the present. Subject: HUNTER MATHEW GRI~'~E 190 PINE SCHOOL ROAD, GARDNERS, PA 17324 Date of Birth: 08-08-1997 $U10-368534 9 03 92--L02 CERTIFICATE PIlEREqUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE ~009.22 IN THE MATTER OF: HUNTER MATHEW GRIFFIE COURT OF COMMON PLEAS TERM, -VS- JURGENSEN, ET AL CASE NO: 02-736 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL BADOWSKI, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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: 09~03~2002 MICHAEL BADOWSKI, ESQUIRE Attorney for DEFENDANT DEll-357010 903 92--L0 3 COPIIVlOI~-%~":AT-TH OF PENNSI'I.V~%I~iA COUI~TY OF CUlWRER! -4/~D IN THE NATTEE OF: ~ MAT~EW GRIFFIE~ JuKGENSEN, ET AL COU~T OF CO~ON PLEAS TERH, CASE NO: 02-736 NOTICE OF I~TENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND Tu~NGS FOR DISC09~.R~ PURSUANT TO RULE 4009.2] HILTON HERSHEY MEDICAL CENTER CARl. ISLE HOSPITAL OTHER CI~BE~LANDIPEP~y CNTY MENTAL 01~E~ UNITED CERBRAL PALSY CAPITAL O'rm~a TO: JOSEPH A. RICCI, ESQ. NELL ROV~.~, ESQ. HCS on behalf of HICHAEL BADOI/Si[I, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~enty (20) days frm the date listed belo~ in vhich to file of record end serve upon the undersigned an objection to the subpoena. If the t~enty day notice period is waived or if no objection is made, then the subpoena m,y be served. Co~lete copies of any reproduced records may be ordered at your expense by coa~leting the attached counsel card and returning same to HCS or by contacting our local HCS office. DATE: 0811212002 CC: MICHAEL BADO~E/, ESQUIRE DARRYL SCRLAPPICH - 57300-4-00134 - 33800001 Any questions regarding this matter, contact MCS on behalf of MIC~L~n. BADO~S~, ESqU~ Attorney for DE~EJCDANT 1601 HAHKET ST~T ~80o PHILADKLPHXA, PA 19103 (215) 246-0900 DE02-196667 90392--C03 HUNTER MATHEW GR~F~iE_ -VS- JURGENSEN, ET AL COMMONWEALTH OF PENNSYLVANIA .COUNTY OF CUMBERLAND File No. 02-736 SUB.P__:QENA TO PRODUCE DOCUMENTS OR THIN S FOR DISCOVERY PURSUANT TO RULE TO: CUSTODIAN OF RECORDS FOR: MILTON HERSHEY MEDICAL CENTER (Na~e olr P~son or Eattty) Within ~,venty (20)days a~er service of thi. ,ubpoena, you ate ord~~D to prod.'.c, the following documer~ or things: at THE MCS GROUP, INC., 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA -~-- (Add~) 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, wi:bin I~,enty (20) days a~ter its service, the patty s~cving 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: MICRAEL BADOWSKI, ESQUIRE ADDRESS: 3510 TRINDLE ROAn CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT iD ~ A~rORNEY FOR: ~ DE~NDANT DATE: 09/03/2002 BY THE COURT: Pm~honotl~/Cll~r~ Civil Division Seal o~ the Court EXPI ANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE PO BOX 850 HERSHEY, PA 17033 RE: 90392 HUNTER MATHEW GRIFFIE ANY AND ALL DIAGNOSTIC FILMS, PRODUCTION OF ALL RADIOGRAPHIC FILMS AND IN PARTICULAR COPIES OF CRANIAL ULTRASOUND FILMS. Subject: HUNTER MATHEW GRIFFIE 190 PINE SCHOOL ROAD, GARDNERS, PA 17324 Social Security ~. 210-76-5074 Date of Birth: 08-08-1997 SU10-391408 903 92--L03 CE~?IFICA~E PREltEqUISlI'E TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: HUNTER MATHEWGRIFFIE COURT OF COf~40N PLEAS TERM, -VS- 3URGENSEN, ET AL CASE NO: 02-736 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL BADOWSKI, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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: 09/03/2002 MCS on behalf of MICHAEL BADOWSF. Ir ESQUIRE Attorney for DEFENDANT DEll-357011 90392--L0 4 COI~IPIOI~-~,~ALTH OF PENNSYLVANIA COUNTY OF CI31~BERLAND IN THE MATTER OF: HUNTER MATHEW GR~FFIE ' JURGENSEN, ET AL COURT OF C0~0N PLEAS TERM, CASE NO: 02-736 NOTICE OF INTENT ~O SERVE A S~]R~'OE~A ~O PRODUCE DOCrm~.~TS T~INGS FOR DISCOYz~ PU~Sr~%~ ~O ~,,.~- 4009.21 M~LTON HE~S~B~Y MI~.~ICAL CENTEH OTHE~ CARLISLE HOSPITAL OTHER CU~4B~nAWD/PE~Ry CNTY MENTAL OTHER UNITED C~,B~. PALSY CAPITAL OTHER TO: NEIL ROVNE~, ESQ.' JOSEPH A. RICCI, ESQ. HCS on behalf of HICN~I. BADOI/S~I, EsquIRE intends to serve a subpoena identical to the one that is attached to this notice. You have t~enty (20) days from the date listed belo~ in which to file of record and serve upon the undersigned an objection to the subpoena. If the t~nty day notice period is waived or if no objection is made, then the subpoena tony be served. C~u~lete copies of any reproduced records may be ordered at your expense by c~letin8 the attached counsel card and returning same to NCS or by contactin8 our local MCS office. DATE: 0811212002 CC: HICRA~. BADO~SE/, ESQUIRE DARRYL SCHLAPPICH - 57300-4-00134 - 33800001 NCS on behalf of H~CHAEL BADO~SK~, ESQUIRE Attorney for DEFENDANT Any questions resardin~ this matter, contact TUaNCS GROUP INC. 1601 NAR~ET STRUT #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-196666 90392--C03 -VS - JURGENSEN, ET AL COMMONWEALTH OF PENNSYLVANI.~ COUNTY OF CUMBERLAND File No. 02-736 SUBPOENA TO PRODUCE DOCUMENTS OR TH~INGS FOR DISCOVERY PURSUANT TO RULE 4009/: TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL (Name of Per, on or Ea~,) Within tWenty (20) days after service of this subpoena, you are ordered by the court to produce the following document~ or thin~: SEE ATTACHED at THE MCS GROUP, INC., 1601 MARKET STREET, SUITE 800, PHILADELPHIA------~rT~~-- (Address} You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, wi:hin tWenty (20) days after its service, the party scoring this subpoena may seek a court order compeliing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL BADOWSKI, ESQUIRE ADDRESS: 3510 TRINDLE ROAD CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: A'I'I'ORNEY FOR: THE DEFENDANT DATE: 09/03/2002 BY THE COURT: Prothonotary/Clerk, Civil Division Seal of the Court left_ 7197% EXPI ANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPIT'P~L 246 PARKER STREET CARLISLE, PA 17013 RE: 90392 HUNTER MATHEW GRIFFIE ANY AND ALL DIAGNOSTIC FILMS; THIS REQUEST IS NOT FOR CHART COPIES, BUT, RATHER SPECIFICALLY FOR RADIOGRAPHIC FILMS INCLUDING COPIES OF CRANIAL ULTRASOUND FILMS. Subject: HUNTER MATHEW GRIFFIE 190 PINE SCHOOL ROAD, GARDNERS, PA 17324 Social Security ~. 210-76-5074 Date of Birth: 08-08-1997 SU10-391410 90~ 92--L04 CERTIFICATK PREKEQUISITE TO SERVICE OF A SUBPOi~*uA PURSUANT TO RULK 4009.22 IN THE MATTER OF: HUNTER MATHEW GRIFFIE COURT OF CO~94ON PLEAS TERM, -VS- 3URGENSEN, ET AL CASE NO: 02-736 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL BADOWSKI, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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: 09/03/2002 MCS on behalf of MICHAEL BADOWSKI, EsquIRE Attorney for DEFENDANT DEll-357012 9 0392--L05 ¢OI~I~O~ALTH OF PENNSYLV~d~IA CO~J~ITY OF IN THE MATTER OF: HUNTER MATHE%I GRIFFIE ' JURGENSEN, ET AL COURT OF C0/~40N PLEAS TERN, CASE NO: 02-7:36 ~LTON HEHS~f ~ICAL CENTEH OT~u~ CAHLISLE HOSPIT~ O~ ~/p~uy C~ ~ O~ ~'f~ C~ar. P~SY ~IT~ O~ ~: ~IL HOV~K, ESQ.' JOSEPH A. ~CCI, ESQ. ~S ~ behalf of ~C~ ~~ KSq~ ~t~ds to se~ a su~ [d~t[cal to ~e ~e ~t i8 arrayed to ~8 notice. Y~ h~ ~nty (20) ~ys frm the ~e l~8ted ~l~ ~ ~ to f~le of reco~ ~d 8e~ ~ ~ders[~ed ~ object~ to ~e s~o~. If ~ ~ty ~y not~ce ~r[~ ~[ved or if no object~ is rode, ~en the s~po~a my be se~ed. C~lete copies of ~y reprod~ed records my ~ or. red at y~ e~ee ~ c~let~K ~e attached c~8el card ~d retu~ sm to ~S or ~ c~tac~ ~r l~al ES office. DATE: 08112~2002 CC: MICwA~- ~A~Ot~eT. KSQUI~ D~BUyL S(3~PpI~ - 57300-4-00134 - 33800001 lES on belmlf of Af.t. ozneF for baL-nmJAi~ Any questions regarding this matter, c~tact 1'HE MOS (~0UP IlJC. 1601 MARKET SI'IKgT d~800 Pu-I. LADKLPH'T-A, PA 19103 (215) 246-0900 DK02-196668 90392--C:03 ,COMMONWEALTH OF PENNSYLVANLL ,COUNTY OF CUMBERLAND - HUNTER MATHE~ GR~FF~'E -VS- JURGENSEN, ET AL File No. 02-736 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009_~-~ TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND/PERRY COUNTY MENTAL ~RALTH (N~me ot~ P:~.Gn or GnHty) Within twenty (20) days after ~rvice of this subpoena, you ar~ ordered by the court to produce thin~: SEE ATTACHED the following dorum~tt~ or at THE MCS GROUP, INC., 1601 MARKET STREET, SUITE 800, (Add....) You may deliver or mail legible copies of the document~ or produce thin~ requested by this subpoena, together with the certificate of compliance, to the party making this requ~t at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copi, or producing the thin~ ~ought. ff you trail to produce the documents or thing~ required by this subpoena, within twenty (20) days a~ter its service, the party sc~ving ~hi3 subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL BADOWSKI, ESQUIRE ADDRESS: 3510 TRINDLE ROAD CAMP IiILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFENDANT DATE: 09/03/2002 BY THE COURT: Pr~honotary/Cl~,k, Civil Div~ion Seal of the Court (Eft. 7/97) EXPLANATION OF R~QUIR~D R~CORDS TO: CUSTODIAN OF RECORDS FOR: CUMBERLAND/PERRY CNTY MENTAL HEALTH-301 HUMAN SVC.BLDG 16 W. HIGH STREET CARLISLE, PA 170132963 RE: 90392 HUNTER MATHEW GRIFFIE ANY AND ALL RECORDS. SubjeCt: HUNTER MATHEW GRIFFIE 190 PINE SCHOOL ROAD, GARDNERS, PA 17324 Social Security ~. 210-76-5074 Date of Birth: 08-08-1997 SU10-391412 90392--L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: HUNTER MATHEW GRIFFIE COURT OF C0~940N PLEAS TERM, -VS- 3URGENSEN, ET AL CASE NO: 02-736 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL BADOWSKI, EsquIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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 i/ltent to serve the subpoena. DATE: 09103/2002 MCS on behalf of MICHAEL BADOWSKI, ESQUIRE Attorney for DEFENDANT DEll-357013 90 392--L06 CO~40~Vw-]~ALTH OF PENNSYLVANIA COUI~TY OF C%~W~EpJ~D IN THE MATTER OF: HUNTER MATHEWG~FFIE' JURGENSEN, ET AL COURT OF CO~40N PLEAS CASE NO: 02-736 NOTICE OF INTENT TO SERVE A SUBPOF~ TO PRODUCE 'l"'dl~JG~ FOR DISCOv~K~ PUI~,,~--A#T TO R~.R 4009.21 ~LTONH~HS~MEDICAL CEITI~H OTHER CAHLISI~ HOSPIT~ O~ ~na~/p~y C~~ 0x~ TO= ~IL ~. ESQ. JOSEPH A. ~I, ESQ. ~S ~ be~lf of ~CNa~. ~~ E~ ~t~ds to se~ a subp~ identical to ~e ~e ~t ~s atta~d to ~ not,ce. You ~ve ~nty (20) ~ys fr~ the ~te l~sted ~1~ ~ to ~le of record ~d se~ u~ ~ders~ed ~ objecti~ to ~e su~. If ~e ~ty ~y not~ce ~ri~ ~ved or if no object[~ is ~de. ~ the su~ ~y be se~ed. C~le~e copies of ~y repr~uced records ~y ~ or,red a~ y~ e~se ~ c~let~ the attached co~sel card ~d retu~ s~ to~S or ~ c~act~ ~r l~al ~S off~ce. 08112/2002 CC: NZC~Am. BADOIJ~i~, ESqU'~,g - 57300-4-00134 - 33800001 Any questions regard/rig th/s matter, contact I~CS on behalf of NZC~Am. BADowsrr~ ES~Ulee Attorney for D~ TBBNCS GROUP IBC. 1601 ~ Sl'gmef /800 PIYZLADELPBT_.A, PA 19103 (215) 246-0900 D~OZ-196&66 90392--C03 HUNTER MATHEW -VS- JURGENSEN, ET AL COMMONWEALTH F PENNSYLV COUNTY OF CUMBERLAND ~leN~ 02-736 SUBPOENA T PR D DOCUMENTS OR ~G F RDISCOVERYPU U T R E4009.22 TO: CUSTODIAN OF RECORDS FOR: UNITED CERBAL PALSY CAPITAL AREA CHILDRENS cENTER (Name e~ ~ e~ EarfUl Within twenty (20) days after service of this subpoma, you are orde~d by ' .. thin[s: the court to produce the foilowlns d°ctsmems or HED at UP INC. 1601 MARKET STREET, SUITE 800, PHILADELPHIA -- ¢A44.~) -------------- You may deliver or mail les:Jble copie~ of the documents or produce thinp requanted by this sublxMna' tos~her with the certificate of compliance, to the party advance, the mahins this request at the address listed above. You have the riehl to seek. in reasonable cost of J~epm'tns the copjeo or producin[ tim thinp sou~t. If you fail to produce the dorum~nts or thfnp requi~ed by this subpoena, within twenty s¢~ifl~ thi~ sub~oeaa may seek a court order compoiiif~ you to comply with it. (20} days ~fter its service, the par~ THIS SUBPOENA WAS ISSUED AT THI: REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL BADOWSKIt ESQUIRE ADDRESS. ~51o TnTNDLE ROAD C~hO~ ~TT,T. PA 17011 TELEPHONE: (~!~ ~46-0900 SUPR£M~ COURT ID ~ A3'FORNEy FOI~ THE DE~EN~ANT DATE: _. 09/03/2002 EXPI,ANATION OF RF. QUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: UNITED CERBRAL'PALSY CAPITAL AREA CHILDRENS CTR. 44 S. 38TH STREET CAMP HILL, PA 17011 RE: 90392 HUNTER MATHEW GRIFFIE ANY AND ALL RECORDS. SubjeCt: HUNTER MATHEW GRIFFIE 190 PINE SCHOOL ROAD, GARDNERS, PA 17324 Social Security ~ 210-76-5074 Date of Birth: 08-08-1997 $~10~391414 90392--1'-06