HomeMy WebLinkAbout02-19-13
Thomas A. French, Esquire M r-" 4D
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Attorney I.D. No. 39305 rn a
Nicole Radziewicz, Esquire rte" _ b t=
Attorney I.D. No. 314061 D C.0 tf r`
RHOADS & SINON LLP .
One South Market Street C
P.O. Box 1146 C ` . -=I o
Harrisburg, PA 17108-1146
(717) 233-5731
Attorneys for Petitioner, Frederick Schrader CO cr' ~
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IN RE: ) IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
JOAN SCHRADER, ) ORPHANS' COURT DIVISION
an Incapacitated Person )
NO. 2013-168
MOTION TO ENFORCE SUBPOENA DIRECTED AT HOLY SPIRIT HOSPITAL FOR
THE MEDICAL RECORDS OF ALLEGED INCAPACITATED PERSON JOAN
SCHRADER
NOW COMES, Frederick Schrader ("Petitioner"), by and through his attorneys, Rhoads
& Sinon LLP, and files the within Motion to Enforce Subpoena Directed at Holy Spirit Hospital
for the Medical Records of Alleged Incapacitated Person Joan Schrader, and in support thereof
avers as follows:
1) Petitioner, Frederick Schrader, is the brother of Joan Schrader, a woman alleged
to be incapacitated as defined under the Pennsylvania Guardianship Act, 20 PA. CONS. STAT.
ANN. § 5501 et seq.
2) On February 11, 2013, Petitioner filed an Emergency Petition to Adjudicate Joan
Schrader Incapacitated and Appoint a Plenary Guardian of her Estate. The petition is attached
hereto as Exhibit "A" and is incorporated herein by reference.
3) Emergency guardianship appointments are sought when there is a risk that
irreparable harm will result to the alleged incapacitated individual without judicial intervention.
See 20 PA. CONS. STAT. ANN. § 5513 (West).
877073.2
4) Petitioner has reason to believe that the appointment of an emergency guardian
for Joan Schrader is necessary to avoid immediate irreparable harm to her estate.
5) At the emergency guardianship hearing, scheduled for February 19, 2013, the
Petitioner must provide evidence related to Joan Schrader's physical and mental health, which
requires the introduction of her medical records.
8) Accordingly, on February 15, 2013, pursuant to Pennsylvania Rule of Civil
Procedure 4009.21, Petitioner issued a subpoena commanding that Holy Spirit Hospital of the
Sisters of Christian Society, d/b/a Holy Spirit Hospital and Holy Spirit Behavioral Services
(hereinafter collectively "Holy Spirit Hospital"), produce Joan Schrader's discharge summaries
and medical records in connection with Holy Spirit's treatment of Joan Schrader and outpatient
records of Psychiatric treatment of Joan Schrader; the Petitioner is not requesting inpatient
mental health records. Copies of the subpoenas that were issued and served are attached hereto as
Exhibit "B" and are incorporated herein by reference.
9) Notwithstanding the subpoenas, Holy Spirit Hospital represented that it would not
produce the medical records without a Court Order.
10) The records sought by the Petitioner do not include inpatient mental health
treatment records, therefore the confidentiality provisions of the Pennsylvania Mental Health
Procedures Act ("MHPA") are inapplicable. See 50 PA. STAT. ANN. § 7103 (West); Gormley v.
Edgar, 995 A.2d 1197, 1203 (Pa. Super. Ct. 2010) (stating, that the confidentiality provisions of
the MHPA "do[] not extend to "treatment [that] was voluntary and provided on an outpatient
basis.
11) To the extent that the Health Insurance Portability and Accountability Act
("HIPAA") is implicated, the exception to the disclosure rule for subpoenas issued pursuant to a
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judicial proceeding is applicable; Joan Schrader has received notice and an opportunity to object.
45 C.F.R. § 164.512.
12) Consequently, Holy Spirit Hospital has no legal justification or basis supporting
its refusal to produce Joan Schrader's medical records and discharge summaries.
13) Holy Spirit Hospital is aware that the present Motion is being filed to enforce said
subpoena and has indicated that its records custodians will bring the records at issue with them to
the emergency hearing and produce them if ordered to do so by the Court.
WHEREFORE Petitioner Frederick Schrader respectfully requests that this Honorable
Court grant his Motion to Enforce Subpoena Directed at Holy Spirit Hospital For the Medical
Records of Alleged Incapacitated Person Joan Schrader, and direct Holy Spirit to produce the
requested records.
RHOADS & SINON LLP
By:
Thomas A. French
Nicole J. Radziewicz
Rhoads & Sinon LLP
One South Market Square
P. O. Box 1146
Harrisburg, PA 17108-1146
(717) 233-5731
Attorneys for Petitioner, Frederick Schrader
3
•
Thomas A. French, Esquire
Attorney I.D. No. 39305 RECORDED OFFICE OF
Jillian M. Golden, Esquire OF %,7I LLS
Attorney I.D. No. 206510 REGISTER ° `
RHOADS & SINON LLP
One South Market Street %1113 FEB 11 PM 9 24
P.O. Box 1146
Harrisburg, PA 17108-1146 CLERK OF
(717) 233-5731
Attorneys for Petitioner, Frederick A. Schrader O R P H A N S' COURT
CUMBERLAND CO., PA
IN RE: ) IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
JOAN SCHRADER, ) ORPHANS' COURT DIVISION
an Incapacitated Person )
)NO. 74013-1(01B
EMERGENCY PETITION TO ADJUDICATE JOAN SCHRADER INCAPACITATED
AND APPOINT A PLENARY GUARDIAN OF HER ESTATE
TO THE HONORABLE JUDGE OF SAID COURT:
1. Petitioner, Frederick A. Schrader ("Petitioner") files the within Emergency
Petition and seeks to have his sister, Joan Schrader, adjudicated an incapacitated person and to
have a plenary guardian of her estate appointed pursuant to Sections 5511 and 5513 of the
Pennsylvania Probate, Estate and Fiduciary Code, 20 Pa. C.S. §§5511- 5513.
2. Joan Schrader ("Ms. Schrader"), the alleged incapacitated person, maintains a
residence at 508 Conklin Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. On January 22, 2013, Ms. Schrader was admitted to Holy Spirit Hospital in Camp
Hill, Pennsylvania after reportedly falling two or more times in the month of January and
because of her extreme mental confusion.
4. Petitioner was advised by the staff at Holy Spirit that Ms. Schrader was
discharged from Holy Spirit Hospital on February 6, 2013.
5. Ms. Schrader is currently rehabilitating on a restricted ward at Forest Park Health
Care & Rehabilitation, 700 Walnut Bottom Road, Carlisle, Pennsylvania 17013.
6. Ms. Schrader is 72 years old.
7. Ms. Schrader is unmarried but has maintained an apparently platonic relationship
for the last twenty (20) years with Gary Fisher ("Mr. ' Fisher"). Mr. Fisher resides with Ms.
Schrader at her Mechanicsburg residence.
8. Mr. Fisher was never employed during their time together and Ms. Schrader's
substantial assets have been the sole source of income for both throughout their 20- year
relationship.
9. Ms. Schrader does not have any children, and her parents are deceased.
10. Ms. Schrader does not employ any service providers.
11. The names and addresses of Ms. Schrader's living next of kin are as follows:
• Frederick A. Schrader (brother and Petitioner herein) of 2715 Carter Farm
Court, Alexandria, Virginia, 22306;
• Peter H. Schrader (nephew) of 37 Congress Street, Keene, New
Hampshire, 04031;
• Andrew B. Schrader (nephew) of 240 Third Avenue, No. 843, Niwot,
Colorado, 80544;
• David A. Schrader (nephew) of 2916 Lee Road, Silver Lake, Ohio, 44224.
12. Ms. Schrader was employed for 25 years as a research librarian but has not
worked since the early 1990's. She is financially dependent on the inheritance received from her
parents, which, through prudent investment by Petitioner, has grown to approximately three
million dollars ($3,000,000). Ms. Schrader also receives a small pension and social security
income.
13. Petitioner has no interest that is adverse to Ms. Schrader. He is not a fiduciary to
Ms. Schrader, nor does he have any interest as a beneficiary of Ms. Schrader's estate. He is not
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the named beneficiary of any trust, retirement account or joint account owned by Ms. Schrader.
Petitioner has simply enjoyed a loving and familial relationship with his sister.
14. Ms. Schrader's long- standing and trusted advisors are Kim Kenawall of Merrill
Lynch and Ms. Schrader's attorney at Saul Ewing, Ryan Gager, Esquire and his assistant,
Marietta Miller ("Ms. Miller").
15. Ms. Schrader maintained a personal relationship with Ms. Miller for almost 20
years and Ms. Miller was one of the only people who Ms. Schrader interacted with on a regular
basis, apart from her family and Mr. Fisher.
16. On February 9, 2011, Ms. Schrader appointed Ms. Miller and her nephew, Peter
Schrader, as her joint powers of attorney.
17. The above-referenced power of attorney was purportedly revoked by Ms.
Schrader on October 5, 2012.
18. No court has ever assumed jurisdiction in a proceeding to determine whether Ms.
Schrader is an incapacitated person and Ms. Schrader has never had a court-appointed guardian.
Joan Schrader Has Substantial Mental And Functional Limitations That
Prevent Her From Receiving And Evaluating Information, Communicating
Decisions, Managing Her Financial Resources And/Or Meeting Essential
Requirements Of Her Physical Health And Safety
19. Throughout her entire life, Ms. Schrader has suffered from chronic and
progressively debilitating mental illness.
20. Ms. Schrader is believed to be bi-polar and manic depressive, and she suffers
from a severe anxiety disorder. It is believed, and therefore averred, that she has been under the
long-term care of her psychiatrist, Dr. Lee C. Miller of East Shore Psychiatric Associates, 2209
Forest Hills Drive, Suite 19, Harrisburg, Pennsylvania, 17112.
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21. It is believed and therefore averred that throughout her life Ms. Schrader has been
highly medicated and is currently taking a cocktail of anti-anxiety and ant-psychotic prescription
medications to stabilize her brain chemistry.
22. Ms. Schrader has been hospitalized numerous times, often due to failure to
properly manage and regulate her medications, resulting in her being either under-medicated or
over-medicated.
23. It is believed and therefore averred that Ms. Schrader's most recent
hospitalization (related to her falling) was compounded by issues with her medications as well.
24. Ms. Schrader has limited to no mobility. She is currently confused, and incoherent
and she threatened to end her own life while in the care of Holy Spirit Hospital. While at Holy
Spirit, she was unaware of her surroundings and suffered from delusions and hallucinations.
25. Prior to her most recent hospitalization, Ms. Schrader would spend up to sixteen
(16) hours a day in bed and had difficulty maintaining her personal hygiene.
26. For the past twenty (20) years, Ms. Schrader has been unable to take care of her
medical, financial or household affairs and has relied on Petitioner, Mr. Fisher, Peter Schrader,
and her advisors at Merrill Lynch and Saul Ewing to handle her day- to- day care and the
management of her financial affairs.
27. It is believed and therefore averred that Mr. Fisher handled the grocery shopping,
paid incidental bills from Ms. Schrader's Merrill Lynch bank account, took Ms. Schrader to
medical appointments and obtained Ms. Schrader's prescriptions, among other day- to- day
tasks.
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28. It is believed and therefore averred that Ms. Miller did personal chores for Ms.
Schrader, such as hiring a home cleaning service, hiring painters, securing lawn care service and
loaning her a wheelchair and arranging for in-home caregivers at Ms. Schrader's residence.'
29. Without the assistance of Petitioner, Mr. Fisher, Ms. Miller and Peter Schrader,
Ms. Schrader could not have lived independently and would have required institutionalized care
and treatment.
30. Ms. Schrader is severely mentally ill with limited mobility, however, she is
otherwise in good health and is expected to live for several more years. It is anticipated that she
will require comprehensive nursing and rehabilitative care, including continued treatment with a
physiatrist.
31. Given Ms. Schrader's current physical state and her history of debilitating mental
illness, Ms. Schrader is an incapacitated person as defined by 20 Pa. C.S. §5501.
Ms. Schrader Is In Need Of A Guardian Of Her Estate And Failure To
Appoint An Emergency Guardian And Thereafter A Plenary Guardian Of
Ms. Schrader's Estate Will Cause Immediate And Irreparable Harm
32. Ms. Schrader's estate is in imminent danger if a guardian is not appointed.
33. An emergency plenary and permanent guardian of Ms. Schrader's estate is
required because Ms. Schrader has never been able to manage her day- to- day care and,
beginning in early to mid-2012, Ms. Schrader fell under the influence of a designing person, Mr.
Fisher, and without capacity to do so, unwittingly provided Mr. Fisher with the ability to make
unlimited and fraudulent gifts to himself in the form of an irrevocable trust for his sole benefit, to
the potential detriment of Ms. Schrader's financial interests.
1 Mr. Fisher fired these in-home service providers because he did not like having people in the
home.
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34. Ms. Schrader's mental and physical health began to further decline in the spring
of 2012 when, while under Mr. Fisher's influence, Ms. Schrader fell,2 was hospitalized, made
several 9-1-1 emergency calls, began to make abrupt and substantial changes to her living and
financial affairs, and uncharacteristically ended relationships with her family and long-term
attorneys and service providers.
Termination Of Longstanding Relationship With Saul Ewing, LLP And
Marietta Miller
35. Ms. Schrader and her family have been clients of Saul Ewing LLP for over 20
years.
36. Ms. Schrader maintained a friendship with Ms. Miller and trusted Ms. Miller to
assist her with various changes to her will over the years.
37. In June 2012, Ms. Schrader abruptly and without prior notice, terminated her
attorney-client relationship with Saul Ewing.
38. Petitioner counseled his sister on this issue and expressed his concern that she was
making a mistake by terminating this attorney-client relationship.
39. Ms. Schrader ignored Petitioner and is no longer a client of Saul Ewing.
40. Ms Schrader has ceased all contact with Ms. Miller.
Sale Of Family Home And 9-1-1 Emergency
41. On March 12, 2012, Ms. Schrader sold the family home, located at 261 North 29`"
Street, Harrisburg, Dauphin County, Pennsylvania, and moved to an assisted living facility,
Bethany Village, in Mechanicsburg, Pennsylvania, with Mr. Fisher.
z Although, when asked about the incident, Ms. Schrader stated that she couldn't remember how
she was injured.
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42. In order for Mr. Fisher to be permitted to live with Ms. Schrader in the residence,
he had to have independent means such that if Ms. Schrader passed away, he could continue to
pay the expenses of living at Bethany Village. At that time, Ms. Schrader made a gift of
$300,000 to him in an irrevocable trust.
43. After relocating to Bethany Village, a continuing care facility, Mr. Fisher
convinced Ms. Schrader that they were being too closely "monitored" by the support staff there.
44. Mr. Fisher decided that they should leave Bethany Village and convinced Ms.
Schrader to purchase a ranch home in Cumberland County.
45. In July 2012, Ms. Schrader reportedly fell and injured her leg while in the shower
at Bethany Village. She was hospitalized and rehabilitated at Manor Care Nursing Home
throughout August 2012.
46. Ms. Schrader never returned to Bethany Village. While Ms. Schrader was at
Manor Care, Mr. Fisher moved their Bethany Village apartment directly to the new Cumberland
County residence.
47. When the staff at Bethany Village were advised that Ms. Schrader had been
persuaded to leave, the staff were gravely concerned and contacted Ms. Schrader's nephew and
power of attorney, Peter Schrader, to discuss their concerns for Ms. Schrader. In addition, it has
also been alleged that, during this period, at least two 911 calls were made, resulting in
emergency responses for medical and domestic issues.
48. At the time, concern was expressed that Mr. Fisher was exercising undue
influence over Ms. Schrader, and that Mr. Fisher was taking advantage of her and not acting in
her best interest.
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Through Exercise Of Undue Influence At A Time When Ms. Schrader
Lacked Sufficient Capacity, Gary Fisher Procured An Appointment As
Power of Attorney, Vested with Right to Deprive Ms. Schrader Of All Of Her
Means Of Support.
49. In or around October 2012, Mr. Fisher convinced Ms. Schrader to terminate her
existing power of attorney, to draw up a new power of attorney naming Mr. Fisher and an
individual by the name of John Fraelish as her agents in fact (with the power to act
independently).
50. Mr. Fraelish has since renounced his appointment as Ms. Schrader's agent.
51. It is believed and therefore averred that Mr. Fisher caused Ms. Schrader to
execute a power of attorney which vests him with the individual power to create an irrevocable
trust in his name alone and for his sole benefit.
52. Petitioner fears for his sister's welfare and maintenance if Mr. Fisher is afforded
with unrestricted access over Ms. Schrader's estate and is able to deprive her of financial
wherewithal to pay for the best quality care she can receive.
53. Mr. Fisher has never held a long- term job, other than a tour of duty in the
military some forty (40) years ago, and has never been vested with financial authority for Ms.
Schrader other than the ability to pay routine bills from his monthly allowance.
54. Mr. Fisher is incapable of providing the comprehensive personal and financial
management that Ms. Schrader's estate requires and is in a position to cause immediate and
irreparable harm to Ms. Schrader should he exercise authority under the power of attorney to
transfer all of her assets to a trust for his own benefit.
Increasing Isolation From Family And Friends From Early 2012 To Present
55. Beginning in early 2012, Ms. Schrader became increasingly withdrawn from her
family.
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56. When Petitioner called to speak to Ms. Schrader, she would end conversations
quickly.
57. Mr. Fisher would typically answer the phone and listen to any discussion that
Petitioner had with Ms. Schrader.
58. When asked questions over the telephone, Ms. Schrader typically stated that she
"had to get Gary" before she could provide a response.
59. Uncharacteristically, Ms. Schrader declined to spend the 2011 and 2012
Christmas holiday with Petitioner and her nephews as she had done in past years.
60. Likewise, Mr. Fisher has stopped returning Petitioner's phone calls, and Petitioner
was not informed by Mr. Fisher of Ms. Schrader's most recent hospitalization until February 1,
2013, 12 days after she was admitted. Petitioner was also not notified of Ms. Schrader's
discharge from Holy Spirit Hospital on February 6, 2012, until Petitioner called Holy Spirit
Hospital two days later.
There Are No Less Restrictive Alternatives That Would
Protect Ms. Schrader
61. Both Ms. Miller and Peter Schrader have received a letter stating that their powers
of attorney have been revoked and they have no authority to act on behalf of Ms. Schrader and
protect her interests.
62. It is believed and therefore averred that in October 2012, while under the
influence of Mr. Fisher, Ms. Schrader made significant changes to her estate plan and vested Mr.
Fisher with control over her financial affairs.
63. Mr. Fisher is ill-equipped to provide Ms. Schrader with the comprehensive
financial management services she requires to preserve her assets for her long-term physical and
mental health.
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64. Because Ms. Schrader lacks the capacity to authorize changes to her power of
attorney and estate planning documents, the within Petition for Guardianship is the only way to
protect Ms. Schrader's estate from imminent and irreparable harm.
65. Petitioner agrees that, despite recent abuse of his confidential relationship with
Ms. Schrader, Mr. Fisher is a trusted companion of Ms. Schrader and that Ms. Schrader would
want to ensure that Mr. Fisher is provided for financially. As such, Petitioner agrees that Mr.
Fisher should continue to reside at the Cumberland County home and should continue to receive
a monthly allowance of $2,000, as previously permitted by Ms. Schrader prior to her incapacity.
Recommended Guardian Of The Estate
66. Petitioner respectfully submits that M&T Bank should be appointed as the
guardian of the estate of Ms. Schrader.
67. M&T Bank is an experienced corporate fiduciary. M&T Bank has consented to
serve as stated in the executed "Consent to Serve" attached hereto as Exhibit "A".
68. According to the Petitioner's knowledge and belief, the gross value of Ms.
Schrader's estate is approximately $3,000,000. The net income available to Ms. Schrader from
all sources is approximately $135,000
69. M&T Bank does not have an interest that is adverse to Ms. Schrader.
WHEREFORE, Petitioner respectfully requests that the Court, under Sections 5513 and
5511 of the Probate, Estates and Fiduciaries Code, issue a citation to Joan Schrader, Joan
Schrader's next of kin, and to such other persons as the Court directs, to show cause why Joan
Schrader should not be adjudged to be an incapacitated person and plenary guardian of her estate
appointed.
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RH & SIN LLP
I
By.
T as A. French
Ji 1 an M. Golden
Orle South Market Square
P. O. Box 1146
Harrisburg, PA 17108-1146
(717) 233-5731
-11-
VERIFICATION
I, Frederick A. Schrader, verify that the statements made in this Petition are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsification to authorities.
Q.
Frederick A. Schrader
Date: 41 Aa 13
IN RE: ) IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
JOAN SCHRADER, ) ORPHANS' COURT DIVISION
an Incapacitated Person )
)NO. 2013-168
CONSENT TO APPOINTMENT AS PLENARY GUARDIAN OF THE ESTATE
1. The name of the proposed guardian of the estate is: M&T Bank.
2. The proposed guardian has a place of business at: 213 Market Street, Second
Floor, Harrisburg, PA 17101.
3. The proposed guardian is a national bank, with trust powers.
4. The proposed guardian does not have an interest adverse to the alleged
incapacitated person.
5. The proposed guardian is not a fiduciary, or an officer or employee of a corporate
fiduciary, of an estate in which the alleged incapacitated person has an interest; and is not the
surety, or an officer or employee of a corporate surety of such fiduciary.
6. The proposed guardian consents to act as guardian of the estate of Joan Schrader.
Dated: j~ M&T B K
I Bv.
John Campbell, Vice s ent
Personal Trust
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN RE: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
JOAN SCHRADER, an ORPHANS' COURT DIVISION
Incapacitated Person
NO. 2013-168
SUBPOENA TO ATTEND AND TESTIFY
TO: Records Custodian for
Holy Spirit Hospital
503 N. 21" Street
Camp Hill, PA 17011
1. You are ordered by the court to come to Cumberland County Courthouse, Courtroom No. 6, One
Courthouse Square, Carlisle, Cumberland Coun , Pennsylvania on Tuesday, February 19, 2013
at 1:30 p.m. to appear and testify on behalf of Joan Schrader and to remain until excused.
2. And bring with you the following: Discharge reports or summaries of treatment for Joan
Schrader for the last two (2) years, together with a summary of dates of all inpatient and
outpatient encounters for the last ten (10) years, and any and all medical records and nursing care
records for Joan Schrader for the past one (1) year, including clinical records, physical and
rehabilitation records, incident or occurrence reports, nurse records, hospital records, chart notes,
correspondence, consultations, progress notes, doctor's orders, test results, lab reports, medication
and prescription records, history and physical, treatment records, neurology reports, and any other
miscellaneous reports and/or opinions which you have regarding the condition or treatment of
Joan Schrader, DOB: 9/1/1940 and SSN: 562-54-4449.
If you fail to attend or to produce the documents or things required by this subpoena, you may be subject
to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not
limited to costs, attorney fees and imprisonment.
REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa. R.C.P. No. 234.2(a):
Name: Thomas A. French, Esquire
Rhoads & Sinon LLP
Address: P. O. Box 1146
Harrisburg, PA 17108-1146
Telephone: 717-233-5731
Supreme Court ID #39305
BY THE COURT:
f Y, G CTY }~h~~
Date: I ~MI~(PA
Seal of the Court V Deputy
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
IN RE: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
JOAN SCHRADER, an ORPHANS' COURT DIVISION
Incapacitated Person
NO. 2013-168
SUBPOENA TO ATTEND AND TESTIFY
TO: Records Custodian for
Holy Spirit Behavioral Health Services
503 North 215` Street
Camp Hill, PA 17011
1. You are ordered by the court to come to Cumberland County Courthouse, Courtroom No. 6, One
Courthouse Square, Carlisle, Cumberland County, Pennsylvania on Tuesday, February 19, 2013
at 1:30 p.m. to appear and testify on behalf of Joan Schrader and to remain until excused.
2. And bring with you the following: Any and all outpatient records for Joan Schrader for the past
ten_ (10) years, including _psychological or psychiatric records clinical records physical and
rehabilitation records, incident or occurrence reports nurse records hospital records chart notes
correspondence, consultations, progress notes, doctor's orders, test results lab reports medication
and prescription records, history physical, treatment records, neurology reports and any other
miscellaneous reports and/or opinions which you have regarding the condition or treatment of
Joan Schrader, DOB: 9/1/1940 and SSN: 562-54-4449.
If you fail to attend or to produce the documents or things required by this subpoena, you may be subject
to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not
limited to costs, attorney fees and imprisonment.
REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa. R.C.P. No. 234.2(a):
Name: Thomas A. French, Esquire
Rhoads & Sinon LLP
Address: P. O. Box 1146
Harrisburg, PA 17108-1146
Telephone: 717-233-5731
Supreme Court ID #39305
BY THE COURT: ,
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Date: ~C)~_'~ f ~tJ ~C~ICPi~/U
Seal of the Court Deputy