HomeMy WebLinkAbout04-5572VILLARI, BRANDES & KLINE, P.C.
BY: David B. Kline, Esquire
Attorney I.D. No. 58733
8 Tower Bridge - 4' Floor
161 Washington Street
Conshohocken, PA 19428
(610)729-2900
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, HJW
4820 Old Harrisburg Road
Gettysburg, PA 17325
vs.
JOSHUA BORDICK
105 Boyle Road
Fairfield, PA 17320
and
TARA L. REINHOLD
105 Boyle Road
Fairfield, Pa 17320
Plaintiffs,
Defendants
Attorney for Plaintiffs
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. U y - 5S7-7-
CIVIL ?u -
ACTION -LAW
JURY TRIAL DEMANDED
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY:
Please issue a Writ of Summons in Civil Action upon the above-named defendants, Joshua
Bordick and Tara L. Reinhold.
Date: 0 ?
6 /0
Respectfully submitted,
VILLARI, B S & KLINE, P.C.
By:
D d B. Kline, Esquire
ttornev for Plaintiffs
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, H/W
4820 Old Harrisburg Road
Gettysburg, PA 17325
Plaintiffs,
VS.
JOSHUA BORDICK
105 Boyle Road
Fairfield, PA 17320
and
TARA L. REINHOLD
105 Boyle Road
Fairfield, Pa 17320
Defendants.
NO. D `t - S S 7:. (I?Q
CIVIL ACTION -LAW
: JURY TRIAL DEMANDED
PRAECIPE FOR SUMMONS
TO THE PROTHONOTARY:
Issue Summons in Civil Action in the above case.
Writ of Summons shall be forwarded to i Attorney )XX -wiff
,c+
David B. Kline, Esquire
VILLARI, BRANDES & KLINE, P.C.
8 Tower Bridge - 4 h Floor
Conshohocken, Pa 19428
(610)729-2900
Date: November 4, 2004 Attorney I.D. No. 58733
SUMMONS IN CIVIL ACTION
TO: Joshua Bordick and Tara L. Reinhold
You are notified that the Plaintiffs have commenced an action against you.
SEAL OF
THE
COURT
Date: !!? ,2da f
Addresses must be included for all parties.
Prothonotary
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VILLARI, BRANDES & KLINE, P.C.
BY: David B. Kline, Esquire
Attorney I.D. No. 58733
8 Tower Bridge - 4' Floor
161 Washington Street
Conshohocken, PA 19428
(610)729-2900
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, H/W
4820 Old Harrisburg Road
Gettysburg, PA 17325
Plaintiffs,
vs.
JOSHUA BORDICK
105 Boyle Road
Fairfield, PA 17320
and
TARA L. REINHOLD
105 Boyle Road
Fairfield, Pa 17320
Defendants.
Attorney for Plaintiffs
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, David B. Kline, Esquire, attorney for Plaintiffs, hereby certify that a true and correct copy of a Praecipe
for Writ of Summons has been forwarded to the Cumberland County Prothonotary for filing, UPS Next Day
Delivery on this 4th day of November 2004. Prothonotary to issue Writ of Summons upon the above-named
defendants to be served by the Cumberland and Adams County Sheriff.
Respectfully submitted,
VILLARI, BRANI S & KLINE, P.C.
By c
Da. d B. Kline, Esquire
Attorney for Plaintiffs
of ; v)
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VILLARI, BRANDES & KLINE, PC
BY: David B. Kline, Esquire
Attorney ID No. 58733
Eight Tower Bridge, 4`h Floor
161 Washington Street
Conshohocken, PA 19428
(610) 729-2900
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, H/W
4820 Old Harrisburg Road
Gettysburg, PA 17325
vs.
JOSHUA BORDICK
105 Boyle Road
Fairfield, PA 17320
and
TARA L. REINHOLD
105 Boyle Road
Fairfield, PA 17320
Plaintiffs,
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-5572 Civil Term
CIVIL ACTION - :LAW
JURY TRIAL DEMANDED
Defendants
PRAECIPE TO REINSTATE WRIT OF SUMMONS
TO THE PROTHONOTARY:
Kindly reinstate the Writ of Summons that was filed with regard to the above-captioned
matter.
VILLARI, B S & KLINE, P.C.
19
B
Y•
D vid B. Kline, Esquire
ttornev for Plaintiff
Dated: 12/1/2004
'
l
>C7
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, HAW,
Plaintiffs
vs.
JOSHUA BORDICK and TARA
REINHOLD,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-5572 Civil Term
JURY TRIAL DEMANDED
CIVIL ACTION -- LAW
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the undersigned's appearance on behalf of the Defendants,
JOSHUA BORDICK and TARA REINHOLD, with regard to the above-captioned matter.
Respectfully submitted,
Date: 17 0
NEALON, GOVER & PERRY, P.C.
Byl?6CSC'i`
Michael S. Fergu on, Esquire
I. D. # 83882
2411 North Front Street
Harrisburg, PA 17110
717/232•-9900
CERTIFICATE OF SERVICE
AND NOW, this Et day of January, 200 hereby certify that I have served
the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by
depositing a true and correct copy of same in the United States mail, postage prepaid,
addressed to:
David B. Kline, Esquire
VILLARI, BRANDES & KLINE, P.C.
8 Tower Bridge - 4th Floor
161 Washington Street
Conshohocken, PA 19428
Michael S. Ferguson, Esquire
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Casey G. Shore, Esquire
NEALON, GOVER & PERRY
2411 North Front Street
Harrisburg, PA 17110
(717) 232-9900
cshore@nealon-gover.com
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, H/W,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 04-5572 Civil Term
JOSHUA BORDICK and TARA
REINHOLD, JURY TRIAL DEMANDED
Defendants CIVIL ACTION - LAW
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the undersigned's appearance on behalf of the Defendants, Joshua
Bordick and Tara Reinhold, with regard to the above-captioned matter.
Respectfully submitted,
NEALON, GOVER & PERRY
By: L6.4?
tZsey G. Shore, Esquire
I.D. #: 85321
2411 North Front Street
Harrisburg, PA 17110
717/232-9900
Date:
CERTIFICATE OF SERVICE
AND NOW, this /7* day of February, 2005, 1 hereby certify that I have served
the foregoing Praecipe for Entry of Appearance on the following by depositing a true
and correct copy of same in the United States mails, postage prepaid, addressed to:
David B. Kline, Esquire
Villari, Brandes & Kline, P.C.
8 Tower Bridge, 4th Floor
161 Washington Street
Conshohocken. PA 19428
a g". Shore, Esquire
Michael S. Ferguson, Esquire
NEALON, GOVER & PERRY
2411 North Front Street
Harrisburg, PA 17110
(717) 232-9900
mferguson@nealon-gover.com
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, H/W,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
JOSHUA BORDICK and TARA
REINHOLD,
Defendants
NO. 04-5572 Civil Term
JURY TRIAL DEMANDED
CIVIL ACTION - LAW
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
TO THE PROTHONOTARY:
Please withdraw the undersigned's appearance on behalf of the Defendants,
Joshua Bordick and Tara Reinhold, with regard to the above-captioned matter.
Respectfully submitted,
Date:
NEALON, GOVER & PERRY
BY: c-
l?_
Michael S. Ferguson, Esquire
I. D. #: 83882
2411 North Front Street
Harrisburg, PA 17110
717/232-9900
CERTIFICATE OF SERVICE
AND NOW, this I1- day of February, 2005, 1 hereby certify that I have served
the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true
and correct copy of same in the United States mail, postage prepaid, addressed to:
David B. Kline, Esquire
Villari, Brandes & Kline, P.C.
8 Tower Bridge, 4th Floor
161 Washington Street
Conshohocken, PA 19428
Michael S. Ferguson, Esquire
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-05572 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BISSONNETTE KEVIN ET AL
VS
BORDICK JOSHUA ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
BORDICK JOSHUA
but was unable to locate Him
deputized the sheriff of ADAMS
in his bailiwick. He therefore
serve the within WRIT OF SUMMONS
County, Pennsylvania, to
On November 22nd , 2004 , this office was in receipt of the
attached return from ADAMS
Sheriff's Costs: So an
Docketing 18.00
Out of County 9.00
Surcharge 10.00 "mas Kline
Dep Adams County 32.60 e iff of Cumberland County
.00
69.60
11/22/2004
VILLAIR KUSTURISS BRANDES KLIN
Sworn and subscribed to before me
this day of
A.D.
7?
Prothonotary
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-05572 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BISSONNETTE KEVIN ET AL
VS
BORDICK JOSHUA ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT to wit:
REINHOLD TARA L
but was unable to locate Her
deputized the sheriff of ADAMS
in his bailiwick. He therefore
serve the within WRIT OF SUMMONS
County, Pennsylvania, to
On November 22nd , 2004 , this office was in receipt of the
attached return from ADAMS
Sheriff's Costs: So
Docketing 6.00
Out of County .00
Surcharge 10.00 omas Kline
.00 S riff of Cumberland County
.00
16.00
11/22/2004
VILLAIR KUSTURISS BRANDES KLIN
Sworn and subscribed to before me
this 6 t--- day of /
A.D.
Prothonotary' '
In The Court of Common Plelas of Cumberland County, Pennsylvania
Kevin Bissonnette et al
VS.
Joshua Bordick et al
SERVE: Joshua Bordick 04-5572 civil
No.
Now November 8, 2004 L SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Adams County to e----cute this Writ, this
J ?
r ,
Sheriff of Cumberland County, PA
Affidavit of Sen ice
deputation being made at the request and risk of the Plaintiff.
Now, , 20 , at
Within (SEE ATTACHED SHERIFF'S NOT FOUND RETURN)
upon
at
by handing to
a
and iLiC?d k-nown to
Sworn and subscribed before
nee this day of , 20
copy of the original
Lily content , 4- --1
So answers,
D u Shherff .
TT-
SVeriff of Adams County, PA
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
o'clock M. served the
in The Court of Common Pleas of Cumberland County Pennsylvania-
Kevin Bissonnette et al
yrs.
Joshua Bordick et al
SERVE: Tara L. Reinhold 04-5572 civil
No.
Now November 8, 2004
Now,
hereby deputize the Sheriff of
I, SHERIFF OF CUMBERLAND COUNTY, PA, do
Adams
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
r
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
20 , at o'clock M. served the
within _(SEE ATTACHED SHERIFF'S NOT FOUND RETURN)
upon
at
by handing to
a
a.d made known to
copy of the original
X the contents t; lereo?
swers,
STen-i-AeV%_0
De'*ty Sberif?,f , •11
eriff of Adams County, PA
Sworn and subscribed before
me this day of , 20COSTS
SERVICE $
MILEAGE
AFFIDAVIT
S
)ATE RECEIVED
SHERIFF'S DEPARTMENT
ADAMS COUNTY, PENNSYLVANIA
COURTHOUSE, GETTYSBURG, PA 17325
DATE PROCESSED
INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY
SHERIFF SERVICE THE SHERIFF" on the reverse of the last (No. 5) copy of this form. Please
PROCESS RECEIPT, and AFFIDAVIT OF RETURN type or print legibly, insuring readability of all copies.
Do not detach any copies. ACSO ENV.#
1. PLAINTIFF/S/ 2. COURT NUMBER
KEVIN BISSONNEITE and SAMANTHA M. BISSONNEITE, b/w 04-5572 Civil
3. DEFENDANT/SI 4. TYPE OF WRIT OR COMPLAINT:
JOSHUA BORDICK and TARA L. REINHOLD Writ of Summons
SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD.
Joshua Bordick
6. ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE)
AT 105 Boyle Road, Fairfield, PA
7. INDICATE UNUSUAL SERVICE: ? PERSONAL ? PERSON IN CHARGE ? DEPUTIZE ? CERT. MAIL ? REGISTERED MAIL ? POSTED ? OTHER
Now, , 1, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of
County to execute this Writ and make return therof according to law. This deputation being
made at the request and risk of the plaintiff.
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE.
SHERIFF OF ADAMS COUNTY
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave
same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to
any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof.
9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE
David B. Kline Esq. X PLAINTIFF
? DEFENDANT (610) 729-2900
V¦ wr a r-"va• r Vll vvL. v1 Vl IF-U1t1-r vnV r - VV 1TW I TV lf711 G tDGLV TV 1171.7 LIPIC
12. 1 acknowledge receipt of the writ SIGNATURE of Authorized ACSO Deputy or Clerk and Title 13. Date Received 14. Expiration/ WOOM date
or complaint as indicated above. 111-9-2004 12-5-2004
15. 1 hereby CERTIFY and RETURN that 1 ? have personally served, D have served person in charge, ? have legal evidence of service as shown in "Remarks" (on reverse)
? have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the
individual, company, corporation, etc., at the address inserted below by handinglor Posting a TRUE and ATTESTED COPY therof.
16. X I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below)
17. Name and title of individual served
F11h'.lace . A person of suitable age and discretion )dead Order
n residing in the defendant's usual
of abode. ? ?
19. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No., City, Boro, Twp., 20. Date of Service 21. Time
State and ZIP CODE)
REMARKS: Defendant has a forwarding address of 9403 Planetree Circle,
Apt. #312, Owings Mills, Maryland 21117
22. ATTEMPTS Date Mlles Dep.lnt. Date Mlles DeP.lnt. L Date Miles Dep.lnt. Date Miles Dep.lnt. Date Mlles Dep.lnt.
23. Advance Costs 24. 25. 26. 27. Total Costs 26Xff4NVMJWXREFUND
X1.5100 1k- $32.60 Pd. 11/16/0 $117.40 Ck. #11957
SO ANSWER.
AFFIRMED and subscribed to before me this N/A
day of By (9biW Dep. Sheriff) (Please Print or Type)
James W. Muller Dat
11,15/2004
Signature of Sheriff Date
RAYMOND W. NEWMAN 11/15/2004
Prolhonotary0eputy/Notary Public
SHERIFF OF ADAMS COUNTY
MY COMMISSION EXPIRES
I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 391 Date Received
OF AUTHORIZED ISSUING AUTHORITY AND TITLE.
PROTHONOTARY
SHERIFF'S RETURN OF SERVICE
( ) (1 ) The within
upon
defendant by mailing to
, the within named
prepaid,
a true and attested copy thereof at
.__ mail, return receipt requested, postage
on the
The return receipt signed by
defendant on the
made a part of this return.
{ 2 ) Outside the Commonwealth, pursuant to Pa.
and attested copy thereof at
is hereto attached and
R.C.P. 405 (c) (1) (2), by mailing a true
in the following manner:
( ) (a) to the defendant by { } registered { } certified mail, return receipt requested,
postage prepaid, addressee only on the
said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities
that Defendant refused to accept the same. The returned receipt and envelope is attached hereto
and made a part of this return.
And thereafter:
( } (b) To the defendant by ordinary mail addressed to defendant at same address, with the return
address of the Sheriff appearing thereon, on the
I further certify that after fifteen (15) days from the mailing date, I have not received
said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a
proof of mailing.
(3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in
the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily
newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general
circulation in said County for
successive weeks of
The Affidavits
from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made
part of this return.
{ 4 ) By mailing to
by
a true and attested copy thereof at
mail, return receipt requested, postage prepaid,
on the
The returned by the Postal
Authorities marked
is hereto attached.
( } ( 5 ) Other
DATE RECEIVED
SHERIFF'S DEPARTMENT
ADAMS COUNTY, PENNSYLVANIA
COURTHOUSE, GETTYSBURG, PA 17325
DATE PROCESSE[
INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY
SHERIFF SERVICE THE SHERIFF" on the reverse of the last (No. 5) copy of this form. Please
PROCESS RECEIPT, and AFFIDAVIT OF RETURN type or print legibly, insuring readability of all copies.
Do not detach any copies. ACSO ENV.k
1. PLAINTIFF/S/ 2. COURT NUMBER
KEVIN BISSONNETTE and SAMANTHA M. BISSONNETTE b/w 04-5572 Civil
3. DEFENDANT/S/ 4. TYPE OF WRIT OR COMPLAINT:
JOSHUA BORDICK and TARA L. REINHOLD Writ of Summons
SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD.
10 Tara L. Reinbold
6. ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE)
AT 105 Boyle Road, Fairfield, PA
7. INDICATE UNUSUAL SERVICE: ? PERSONAL D PERSON IN CHARGE ? DEPUTIZE ? CEAT. MAIL D REGISTERED MAIL ? POSTED Q OTHER
Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of
County to execute this Writ and make return therof according to law. This deputation being
made at the request and risk of the plaintiff.
SHERIFF OF ADAMS COUNTY
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE.
NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave
same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to
any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof.
9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE
David B. Kline Esq. X PLAINTIFF
11 DEFENDANT (610) 729-2900
Mr ..vr. a+a.w TV IF %f" MMW- yr ar>rGnrrtr v11111L If - luv MW I TV nl l C or-LVYY 11'71, LIIVt
12. 1 acknowledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and Title 13. Date Received 14. Expiration / @rE# " daft
or complaint as indicated above. 11-9-2004 12-5-2004
15. 1 hereby CERTIFY and RETURN that 1 ? have personally served, ? have served person in charge, ? have legal evidence of service as shown in "Remarks" (on reverse)
? have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the
individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therof.
16. I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below)
17. Name and title of individual served 19. A person of suitable age and discretion Read OrdE
than residing in the defendant's usual
place of abode. ? Q
19. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No., City, Boro, Twp„ 20. Date of Service 21. Time
State and ZIP CODE)
REMARKS: Defendant bas a forwarding address of 9403 Planetree Circle,
Apt. #312, Owings Mills, Maryland 21117
22. ATTEMPTS Date Mlles Dep.Int. Date Mlles Dep.lnt. Date Mlles Dep.lnt. Date Mlles Dep.int. Date Mlles Dep.lnt.
23. Advance Costs 1 24. i 25. 1 26.
27. Total Costs 28. COST DUE OR REFUND
SO ANSWER.
AFFIRMED and subscribed to before me this N A
809%6W Dep. Sheriff) (Please Print or Type) Date
day of James W. Muller 11/15/2004
Signature of Sheriff Date
RAYMOND W. NEWMAN 11/15/2004
PrdhonotsrylDspugMotary Public
SHERIFF OF ADAMS COUNTY
MY COMMISSION EXPIRES
I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 39. Date Received
OF AUTHORIZED ISSUING AUTHORITY AND TITLE.
PROTHONOTARY
SHERIFF'S RETURN OF SERVICE
( ) ( 1 ) The within
upon
defendant by mailing to
by
prepaid,
a true and attested copy thereof at
, the within named
- mail, return receipt requested, postage
on the
The return receipt signed by
defendant on the is hereto attached and
made a part of this return.
( ) { 2 ) Outside the Commonwealth, pursuant to Pa. R.C.P. 405 (c) (1) (2), by mailing a true
and attested copy thereof at
in the following manner:
( } (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested,
postage prepaid, addressee only on the
said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities
that Defendant refused to accept the same. The returned receipt and envelope is attached hereto
and made a part of this return.
And thereafter:
{ ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return
address of the Sheriff appearing thereon, on the
I further certify that after fifteen (15) days from the mailing date, I have not received
said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a
proof of mailing.
( } (3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in
the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily
newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general
circulation in said County for
successive weeks of
The Aff idavits
from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made
part of this return.
{ ) (4) By mailing to
by mail, return receipt requested, postage prepaid,
on the
a true and attested copy thereof at
The returned by the Postal
Authorities marked
is hereto attached.
( ) { 5 ) Other
f I
KEVIN BISSONNETTE and : IN THE COURT OF COMMON PLEAS
SAMANTHA M. BISSONNETTE, HNV, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
VS.
NO. 04-5572 Civil Term
JOSHUA BORDICK and TARA
REINHOLD, : JURY TRIAL DEMANDED
Defendants : CIVIL ACTION - LAW
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20)
days or suffer a judgment of non pros.
Date: ll
TO THE PLAINTIFF:
Respectfully submitted,
NEALON. GOVER & PERRY
By
Cii:--e ? G. Shore, Esquire
I.D. #: 85321
2411 North Front Street
Harrisburg, PA 17110
7171232-9900
RULE
A Rule is hereby issued upon you to file a Complaint within twenty (20)
days of service of this Rule or suffer a judgment of non pros.
DATED: N I r
Prothonotary
i r
CERTIFICATE OF SERVICE
AND NOW, this el day of April, 2005, 1 hereby certify that I have served the
foregoing Praecipe for Rule to File Complaint on the following by depositing a true and
correct copy of same in the United States mails, postage prepaid, addressed to:
David B. Kline, Esquire
Villari, Brandes & Kline, P.C.
8 Tower Bridge, 4th Floor
161 Washington Street
Conshohocken, PA 19428
L S La?
Ca. Shore, Esquire
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VILLARI, BRANDES & KLINE, PC
BY: David B. Kline, Esquire
Attorney ID No. 58733
Eight Tower Bridge
161 Washington Street, Suite 400
Conshohocken- PA 19428
Attorney for Plaintiff
610) 729-2900
:EVIN BISSONNETTE and
AMANTHA M. BISSONNETTE, H/W
820 Old Harrisburg Road
jettysburg, PA 17325
Plaintiffs,
vs.
OSHUA BORDICK
nd
'ARA L. REINHOLD
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-5572 Civil Term
CIVIL ACTION - LAW
NOTICE TO DEFEND
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 tiling 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
l
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Stret
Carlisle, PA 17013
(717)249-3166
'ILLARI, BRANDES & KLINE, PC
Y: David B. Kline, Esquire
.ttorney ID No. 58733
ight Tower Bridge
61 Washington Street, Suite 400
onshohocken, PA 19428
610) 729-2900
Attorney for Plaintiff
KEVIN BISSONNETTE and COURT OF COMMON PLEAS
SAMANTHA M. BISSONNETTE, H/W CUMBERLAND COUNTY, PENNSYLVANIA
4820 Old Harrisburg Road
Gettysburg, PA 17325
NO. 04-5572 Civil Term
Plaintiffs,
CIVIL ACTION - LAW
vs.
BORDICK
f ARA L. REINHOLD
Defendants
COMPLAINT
Plaintiffs, by and through the undersigned counsel, hereby file this Complaint and in
thereof, aver as follows:
1. Plaintiff, Samantha Fisher Bissonnette, is an adult individual and maintains a
at 4820 Old Harrisburg Road, Gettysburg, Pennsylvania, 17325
2. Defendant driver, Tara Reinhold, is an adult individual who maintains a residence
9403 Planetreee Circle, Apt. 312, Owings Mills, Maryland, 21117-7544.
3. Defendant owner, Joshua R. Bordick, is an adult individual who maintains a
residence at 9403 Planetreee Circle, Apt. 312, Owings Mills, Maryland, 21117-7544.
4. On or about November 13, 2002, at or about 7:48 a.m., Plaintiff was operating a
1993 Ford F150 truck in the left northbound lane of Route 15, Upper Allen Township,
County, Pennsylvania, when a 1998 Mercury Sable, owned by Defendant Bordick
operated by Defendant Reinhold, collided with the rear end of her motor vehicle, which was
causing damage to both plaintiff and plaintiff s motor vehicle.
5. Defendant Tara Reinhold failed to observe or realize that plaintiff s motor vehicle
come to a stop and that there was a motor vehicle ahead of hers on the same roadway which
had come to a stop.
6. At all times relevant hereto, Plaintiff was bound by her full tort election.
7. As a direct and proximate result of this collision, Plaintiff sustained bodily
injuries, property damage, and other losses, to be described in detail below.
COUNT I - NEGLIGENCE
Samantha Fisher Bissonnette v. Defendant Tara Reinhold
8. Paragraphs 1 through 7, inclusive, of this Complaint are incorporated herein by
as though fully set forth at length.
9. The negligence of Defendant Tara Reinhold, which directly and proximately caused
Samantha Fisher Bissonnette's injuries and other losses, consisted of the following
acts and/or omissions:
(a) Failing to realize or observe that plaintiff's motor vehicle was stopped on the
ahead;
(b) Failing to realize or observe that plaintiff s motor vehicle would have to stop
a motor vehicle ahead of hers, on the same roadway, had previously come to a stop;
(c) Failing to adequately and/or properly control her motor vehicle so as to be
to avoid colliding into plaintiff s motor vehicle;
(d) Failing to stop her motor vehicle before colliding into the rear of plaintiff s
vehicle;
(e) Proceeding ahead in Plaintiffs lane of travel when doing so presented a risk
harm to Plaintiff Samantha Fisher Bissonnette;
(f) Failing to keep a proper lookout for the status of traffic ahead of her, such as
stopped motor vehicle;
(g) Failing to heed traffic ahead when such traffic was stopped in defendant's
of travel;
(h) Traveling too fast, i.e., above the posted speed limit;
(i) Traveling too fast for conditions;
(j) Not slowing down an d stopping for stopped traffic ahead when, in the
of reasonable care, she should have done so; and
(k) Failing to maintain adequate and reasonable control over her motor vehicle
operating it on public roadways.
10. As a direct and proximate result of the negligence of this Defendant, Plaintiff
Fisher Bissonnette sustained the following bodily injuries known to date, and potentially
injuries and/or losses arising from or in consequence of those injuries: lower back pain,
pain, muscle spasms, disc herniation at L4-5 requiring multiple surgeries with right sciatica,
pain and numbness in her extremities, emotional distress and depression because of her
uries and limitations therefrom, and anxiety when riding in a motor vehicle, some or all of which
be permanent in nature.
11. As a further direct and proximate result of the negligence of this Defendant, Plaintiff
Fisher Bissonnette has been, and may continue to be, subjected to further medical
and treatment, and any accompanying risks, hazards, pain, suffering, discomfort, and
losses associated therewith, all to her continuing detriment and loss, as well as past out-of-
medical expenses for which she is liable and future medical expenses for which she may
liable.
12. As a further direct and proximate result of the negligence of this Defendant, Plaintiff
Fisher Bissonnette underwent: Hemilaminotomy and disk excision L4-L5 on right at
Spirit Hospital; "Redo right L4-5 lumbar microdiscectomy" at York Hospital; fluoroscopically
lumbar steroid injections at the L4-5 level, as well as undergoing various tests, medical
and therapies.
13. As a further direct and proximate result of the negligence of this Defendant,
Samantha Bissonnette has been prevented or inhibited from attending to and/or fully
her usual daily routines, activities and pastimes and may be prevented or inhibited fully
doing the same in the future, all to her continuing detriment and loss.
14. As a further direct and proximate result of the negligence of this Defendant, Plaintiff
Fisher Bissonnette has suffered a loss and may suffer future losses because of expenses
have been, or may be, incurred in obtaining ordinary and necessary services in lieu of those
she herself would have performed, not for income but for the benefit of herself, if she had not
so grievously injured, such as child care, home cleaning, chores and maintenance, and the like.
15. As a further direct and proximate result of the negligence of this Defendant, Plaintiff
Fisher Bissonnette has suffered a limitation on her ability to earn income, a reduction of
earning power and capacity, and diminution of her economic earning potential, all to her
detriment and loss.
WHEREFORE, Plaintiff Samantha Fisher Bissonnette demands judgment in her favor and
Defendant Tara Reinhold in an amount in excess of Thirty Five Thousand Dollars
5,000.00), together with such other relief as this Honorable Court may deem fair and just.
COUNT II - NEGLIGENT ENTRUSTMENT/MAINTENANCE
Plaintiff Samantha Fisher Bissonnette v. Defendant Joshua Bordick
16. Paragraphs 1 through 15, inclusive, of this Complaint are incorporated herein by
as though fully set forth at length.
17. Defendant Joshua Bordick was negligent in the following acts and/or omissions:
(a) Entrusting his motor vehicle to another party without first ascertaining the
and/or competence of that party to safely operate a motor vehicle, which in the exercise of
care he should have done;
(b) Entrusting his motor vehicle to another party while knowing that he did not
the fitness and/or competence of that party to safely operate a motor vehicle;
(c) Entrusting his motor vehicle to another party without first knowing the
violations driving record or the driving accident history of that party, which in the exercise
care he should have known;
(d) Failing to properly maintain his motor vehicle so that an operator would be
to steer, brake and stop it in a safe and proper fashion, which in the exercise of reasonable care
should have done;
(e) Failing to have said motor vehicle inspected on the date of loss, which in the
of reasonable care he should have done;
(f) Failing to periodically monitor, test and/or check his motor vehicle prior to
date of loss to reasonably ensure that it was in proper and safe working order and condition, fit
safe operation on the highways of the Commonwealth of Pennsylvania;
(g) Entrusting his motor vehicle to another party without first knowing if that
party had caused any prior motor vehicle accidents, which in the exercise of reasonable care
should have known; and
(h) Entrusting his motor vehicle to another parry without first knowing if that
party possessed a valid driver's license at the time, which in the exercise of reasonable care he
have known.
18. As a direct and proximate result of the negligence of this Defendant, Plaintiff
Fisher Bissonette sustained the bodily injuries and other losses enumerated in paragraphs
0 through 15, inclusive, hereby incorporated by reference as if fully set forth at length.
WHEREFORE, Plaintiff Samantha Fisher Bissonnette hereby demands judgment in her favor
against the Defendants herein jointly and severally, and individually, in an amount in excess of
Five Thousand Dollars ($35,000), together with such other relief as this Honorable Court may
just and fair.
Respectfully submitted,
KLINE, P.C.
By:
David-B. Kline, Esquire
Attorney for Plaintiff
1.
VERIFICATION
David B. Kline, Esquire, hereby states that he is counsel for the plaintiff in this action and
that the statements made in the foregoing pleading are true and correct to the best of his
information and belief, and that this Verification is made with the knowledge,
and consent of Plaintiff. Counsel makes this Verification for the purpose of assuring the
filing of this pleading. The Verification of the party-plaintiff will be substituted at a later
This verification is made subject to 18 Pa.C.S.A. § 4904 which provides for certain penalties
making false statements.
David B. line, Esquire
VILLARI BRANDES & KLINE, P.C.
Attorneys for Plaintiff
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VILLARI, BRANDES & KLINE, PC
BY: David B. Kline, Esquire
Attorney ID No. 58733
Eight Tower Bridge
161 Washington Street, Suite 400
Conshohocken, PA 19428
(610) 729-2900
Attorney for Plaintiff
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, H/W
4820 Old Harrisburg Road
Gettysburg, PA 17325
Plaintiffs,
vs.
JOSHUA BORDICK
and
TARA L. REINHOLD
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-5572 Civil Term
CIVIL ACTION - LAW
PRAECIPE TO SUBSTITUTE ORIGINAL VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached original Verification of Plaintiff, Samantha Fisher Bissonnette
for the Verification of counsel filed with the Plaintiffs' Complaint.
Respectfully submitted,
I
By:
for Plaintiff(s)
VERIFICATION
I, Samantha Fisher Bissonnette, , hereby state that I am a Plaintiff in this action and verify
that the statements made in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief. I understand that the statements therein are made subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities.
b
Saman tha fisher issonnette
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CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-vS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005
MCS?gn .behalf o
CASEY SH E, ESQ.
Attorne for DEFENDANT
DE11-573159 0'7:326-L 03-
COMMONWEALTH O F PENNS YLVAN SA
CUMBERLAND
COUNTY O EP
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-vs-
BORDICK, ET AL
TO SERVE
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
4
[ Note: see enclosed list of locations ]
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0 7 3 2 6- C 0--2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & )[RAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & )RAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0-732G-(--02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. ^ 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULF 4009.22
TO: Custodian of Records for HANOVER GENERAL 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 M 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 FOLLOWNG PERSON:
NAME: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: L-J 1. t 2 1 2 no's
Seal of the Court
BY THE COURT:
Prothonotary/Clerk,
07326-01
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HANOVER GENERAL HOSPITAL
300 HIGHLAND AVE.
HANOVER, PA 17331
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Entire hospital medical file, including but not limited to any and all records,
correspondence to and from the consulting and/or treating physician, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, nurse's notes, doctor's comments, dietary restrictions,
and all patient consent or refusal of treatment, procedures, test, and/or
medication, lab and diagnostic test results, including any and all. such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, diagnosis, care, treatment,
admission, discharge, or emergency care pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, IPA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571336 073:26-L 03-
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, E
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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573160 07:326-T-02
PENNS YLVAN SA
COMMONWEALTH C )EP
COUNTY O F CLIMB E:RLAND
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations )
TO: DAVID B. RUNE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC. CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
Any questions regarding this matter, contact
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 07-32G-C702
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
OTHER & XRAYS
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS f XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS di XRAYS
DE02-305013 0-7326-C!0.2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. _ 04-5572
SUBPOENA TO PRODUCE DOCUMENTS CIR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for. HANOVER GENERAL 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 Groun Inc 1601 Market Street, it 800 P ilad lohia 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST
HARRISBURG . PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: at
Seal of the Court
07326-02
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HANOVER GENERAL HOSPITAL
300 HIGHLAND AVE.
HANOVER, PA 17331
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Any and all x-ray films and reports, including any and all such items as may
be stored in a computer database or otherwise in electronic form,
pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security 1{: 162-68-3272
Date of Birth: 05-16-1979
SU10-571338 07 3.2 6- L 0.2
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573161 0 7 3 2 6- L 03
P ENN S YLVAN SA
COMMONWEALTH (OF'
COLTNTY OF CLIMB E:RLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'T'S AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
I Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0 7 3 2 6- C 0 2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR_
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & )MAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS f XRAYS
MEDICAL RECORDS I XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0-7-324S-(--o.-2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for GETTYSBURG CHIROPRACTIC CTR.
(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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: () 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JU-O -21 a oo.'?"
Seal of the Court
BY THE COURT:
Prothonotary/Clerk,
07326-03
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
GETTYSBURG CHIROPRACTIC CTR.
1080A CHAMBERSBURG ROAD
GETTYSBURG, PA 17325
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not linrited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
8U10-571340 0 7 3 2 6- L 03
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
VS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573162 0 7 3 2 6- L 0 4
PENN3 YLVAN = A
COMMONWEALTH (DIP
COUNTY OF CLIMB E72LAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
( Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ_, PLAIN'T'IFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0-7:326-(--0--2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0'7326-CO2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. _ 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for MRI OF YORK
(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 M Group. Inc.- 1601 Market Street. Suite 800. Philad Inhia. 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: CASEY SHORE. ESO
ADDRESS: 2411 N. FRONT ST
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: .2 ,1 ancA S
Seal of the Court
BY THE COURT:
Prothonotary/Clerk, Civil ivi
Deputy
07326-04
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
MRI OF YORK
2064 SPRINGWOOD ROAD
YORK, PA 17403
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571342 0 732 6- L O4
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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 or., behalf of
DATE: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573163 0-732G -L OS
P ENN:S YLVAN SA
COMMONWEALTH (DIP
CUMB E]RLAND
COUNTY C DIP
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE)
-VS-
TERM,
CASE NO: 04-5572
BORDICK, ET AL
A
TO
[ Note: see enclosed list of locations )
TO: DAVID H. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
Any questions regarding this matter, contact
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0'732E3-r-'0.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS XRAYS
MEDICAL RECORDS 4 XRAYS
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS SXRAYS
DE02-305013 0 7 3 2 6- C 0 2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for NATIONWIDE INSURANCE 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 GrouW_ Inc.. 1601 Market Street- it 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: ?? F of l 1 2 Co S
Seal of the Court
BY THE COURT:
Prothonotary/Clerk,
07326-05
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
NATIONWIDE INSURANCE COMPANY
1000 NATIONWIDE DRIVE
P. O. BOX 2655
HARRISBURG, PA 17105
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Any and all insurance records and PIP files, including but not limited to
medical reports and/or records, claims, any and all correspondence,
documentation supporting plaintiff's claim, payments including dates of
payments, payee and reasons for payments, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
Date of Loss: 11/13/2002
SU10-571344 0 7 :3.2 6- L 0 S
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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 :he 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573164 0 7 3 2 6-T,06
PENN S YLVAN 2 A
COMMONWEALTH C )F
COUNTY (DV CiJMB E:RLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0 7 3 2 6- C 0 2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS XRAYS
INSURANCE
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS fi XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS .? )RAYS
MEDICAL RECORDS ? )RAYS
MEDICAL RECORDS ? XRAYS
IDE02-305013 07326-C02
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS CIR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for TRISTAN 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG- PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: Jf -A-Ne a / o24Gy5
Seal of the Court
BY THE COURT:
Prothonotary/Clerk,
07326-06
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
TRISTAN ASSOCIATES
4518 UNION DEPOSIT ROAD
HARRISBURG, PA 17109
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not linlited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
fihns and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
fSU10-571346 0 7 3 2 6- L 0 6
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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 rece:ved, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573165 0 7 3 2 6- L 0-7
COMMONWEALTH O F PENN S YLVAN SA
CUMBERLAND
COUNTY C )PI
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
TERM,
CASE NO: 04-5572
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO :RULE 4009.21
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ_
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 07:32G-C:0.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MEL OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS IN'T'ERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS Sr XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS Sr .XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS Sr .XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS .& XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0 7 3 2 6- C O I
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE: 4009.22
TO: Custodian of Records for APPLE HILL VASCULAR A O LTD
(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 M Gm=. Inc.- 1601 Market Street- Suit 800. Philadelphia- PA 19]03
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 wit]iin 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG-PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: NJUL-?F 21 ??aC
Seal of the Court
BY THE COURT:
Pr y/Clerk, civil Div''
C/
Deputy
07326-07
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR
APPLE HILL VASCULAR ASSOC.,LTD
25 MONUMENT ROAD
SUITE 105
YORK, PA 17403
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not linuted to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571348 0 7 3 2 6- L 0-7
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, E
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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DEII-573166 0'7326--L 08
COMP?ONWEALTH OF PENN75YLVAN=A
COiTNTY OF CUMB E7E2LAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
SERVE A
TERM,
CASE NO: 04-5572
DOCUMENTS AND
21
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0'7326-C70.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
IDE02-305013 0-7:32E;-C!0--2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS CIR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for YORK 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 Gw=. 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: CASEY SHORE. ES
ADDRESS: 2411 N. FRONT ST.
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY THE COURT:
Civil
Deputy
Date: JuA )F
Seal of the Court
07326-08
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
YORK HOSPITAL
1001 S. GEORGE STREET
YORK, PA 17401
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
MEDICAL RECORDS FROM 1/1/95 TO 6/24/05
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 1624&3272
Date of Birth: 05-16-1979
SII10-571604 07326-L08
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-vS-
BORDICK. ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573167 07:326-L 09
P ENN;S YLVAN =A
COMMONWEALTH 01P
COUNTY OF CUMBE:E2L2%11TD
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations ]
TO: DAVID B. KLINE, ESQ_, PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0'732G-(--0.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR_
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0-7:32G-4--0-2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE: 4009.22
TO: Custodian of Records for YORK 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 500. 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JL ' ) r t- 1
Seal of the Court
BY THE COURT:
Prothonotary/Clerk, Civil Divisio
Deputy
07326-09
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
YORK HOSPITAL
1001 S. GEORGE STREET
YORK, PA 17401
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Any and all x-ray films and reports, including any and all such items as may
be stored in a computer database or otherwise in electronic form.,
pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security N: 162-68-3272
Date of Birth: 05-16-1979
3U10-571352 07326-L O9
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-vS- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573168 07:326-L a_0
PENN'.3 YLVAN SA
COMMONWEALTH C )EP
COUNTY OF' CUMBE72LAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0-732G-C.70.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL MEDICAL RECORDS
HANOVER GEXERAL HOSPITAL X-RAY ONLY
GETTYSBURG CHIROPRACTIC CTR. MEDICAL RECORDS & )[RAYS
MRI OF YORK MEDICAL RECORDS & XRAYS
NATIONWIDE INSURANCE COMPANY INSURANCE
TRISTAN ASSOCIATES MEDICAL RECORDS & XRAYS
APPLE HILL VASCULAR ASSOC.,LTD MEDICAL RECORDS & XRAYS
YORK HOSPITAL OTHER
YORK HOSPITAL OTHER
HOLY SPIRIT HOSPITAL MEDICAL RECORDS
HOLY SPIRIT HOSPITAL X-RAY ONLY
CROSS KEYS INTERNAL MEDICINE MEDICAL RECORDS & )[RAYS
YORK NEUROSURGICAL ASSOCIATES MEDICAL RECORDS & )RAYS
SPIRIT PHYSICIANS SERVICES,INC MEDICAL RECORDS & XRAYS
GETTYSBURG HOSPITAL MEDICAL RECORDS
GETTYSBURG HOSPITAL X-RAY ONLY
ORTHOPEDIC INSTITUTE OF PA. MEDICAL RECORDS Si XRAYS
MAGNETIC IMAGING CENTER MEDICAL RECORDS Si XRAYS
MOFFITT HEART & VASCULAR GROUP MEDICAL RECORDS & XRAYS
HEALTHSOUTH REHAB MEDICAL RECORDS & XRAYS
DE02-305013 0 7 3 2 6- C O I
0
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for HOLY SPIRIT 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 GIOnn. Inc.. 1601 Market Street- Suite 500. 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: CASEY SHORE. ES
ADDRESS: 2411 N. FRONT ST.
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JLl,-'NE .O-/Ta 06C
Seal of the Court
07326-10
EXPLANATION OF REQUIRED ]RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HOLY SPIRIT HOSPITAL
503 NORTH 21ST STREET
CAMP HILL, PA 17011
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Entire hospital medical file, including but not limited to any and all records,
correspondence to and from the consulting and/or treating physician, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, nurse's notes, doctor's comments, dietary restrictions,
and all patient consent or refusal of treatment, procedures, test, and/or
medication, lab and diagnostic test results, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, diagnosis, care, treatment,
admission, discharge, or emergency care pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571354 0 7 3 2 6- L a-0
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573169 07326-L J _:I_
PENNS YLVAN S A
COM1?iONWEALTH C )EP
COUNTY OF CUMBEFZLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
[ Note: see enclosed list of locations 1
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS,on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0-7326-C702
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CIE.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & )[RAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS &: XRAYS
MEDICAL RECORDS &: XRAYS
MEDICAL RECORDS &: XRAYS
DE02-305013 0'7326-(Z!0.2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for HOLY SPIRIT 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JC -.J E- a /r a.0o5
Seal of the Court
07326-11
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HOLY SPIRIT HOSPITAL
503 NORTH 21ST STREET
CAMP HILL, PA 17011
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Any and all x-ray films and reports, including any and all such items as may
be stored in a computer database or otherwise in electronic form,
pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571356 0 7 3 2 6- L 1 1
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-v5-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
IDE11-573170 0 7 3 2 6- L 1-2
P ENN?IYLVAN SA
COMMONWEALTH C DP'
COUNTY OF CLIMBER'LAND
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
OF INTENT TO SERVE A
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
PRODUCE
[ Note: see enclosed list of locations
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0 7 3 2 6- C 0:'2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS &: XRAYS
MEDICAL RECORDS &. XRAYS
INSURANCE
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS &. XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS &. XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0 7 3 2 6- C 0 2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for CROSS KEYS INTERNAL MEDIC 4E
(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: **** S 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: _CASEY SHORE. ES
ADDRESS: 2411 N. FRONT ST
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JL_??
Seal of the Court
07326-12
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
CROSS KEYS INTERNAL MEDICINE
2900 CARLISLE PIKE
NEW OXFORD, PA 17350
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
S'1310-571358 0 7 3 2 6-T-a-2
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-vs- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573171 07326-L a-3
COMMONWEALTH OF' PENN£>YLVAN2A
COI7I17TY OF CUMBERLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
A SUBPOENA TO PRODUCE
RY PURSUANT TO RULE 4
( Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ_, PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ_
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0-7:32G-(--0.'2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GEITYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GEITYSBURG HOSPITAL
GEITYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0-732G-(Z70.'2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for YORK NEUROSURGICAL 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 Grogp. Inc., 1601 Market Street. Suite 800. Philadelphia. PA 1911)3
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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JLIA? ?? / ' 2,.n 6 5
Seal of the Court
07326-13
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
YORK NEUROSURGICAL ASSOCIATES
2319 SOUTH GEORGE STREET
YORK, PA 17403
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571360 0 7 3 2 6- L 3_3
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-vS-
BORDICR, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573172 0 7 3 2 6- L 3-4
COMMONWEALTH O F PENN a YLVAN =A
COUNTY O EP CUMBERLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE)
-vs-
TERM,
CASE NO: 04-5572
BORDICK, ET AL
NOTICE
TO
( Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
Any questions regarding this matter, contact
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0'732G-4Z-'0.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS d: XRAYS
MEDICAL RECORDS d: )[RAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS d: )RAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS d: XRAYS
MEDICAL RECORDS d: XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS Si XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0-7:32E;-C!0--2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS CIR THINGS
FOR DISCOVERY PURSUANT TO RULE: 4009.22
TO: Custodian of Records for SPIRIT PHYSICIANS SERVICES.21C
(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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: % l LA -2 1. ?2 6cks:
Seal of the Court
07326-14
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
SPIRIT PHYSICIANS SERVICES,INC
DEVONSHIRE FAM HEALTH CTR
4300 DEVONSHIRE ROAD
HARRISBURG, PA 17109
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
film and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571362 07326-L 3_-11
CERTIFICATE
PREREQUISITE TO SERVICE OF A S1I13POENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573173 0 7 3 2 6- L 1 S
PENN3 YLVAN S A
COMMONWEALTH OF
COiTNTY OF CUMBEI2LA11TD
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
TERM,
CASE NO: 04-5572
A SUBPOENA TO PRODUCE
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
EIE02-305013 0 7 3 2 6- C 0 2-
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAT. MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART 6 VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS d. XRAYS
MEDICAL RECORDS d. XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & )CRAYS
MEDICAL RECORDS & )CRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS d: XRAYS
MEDICAL RECORDS dXRAYS
MEDICAL RECORDS )CRAYS
MEDICAL RECORDS d, )CRAYS
DE02-305013 0-732G-C70--2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for GETTYSBURG 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JO -)g a 1t al _S
Seal of the Court
BY T E COURT:
2 .
Prothonotary/Clerk, Civil Divisio o /
Deputy
07326-15
EXPLANATION OF REQUIRED ]RECORDS
TO: CUSTODIAN OF RECORDS FOR:
GETTYSBURG HOSPITAL
147 GETTYS STREET
GETTYSBURG, PA 17325
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Entire hospital medical file, including but not limited to any and all records,
correspondence to and from the consulting and/or treating physician, files,
memoranda, handwritten notes, history and physical reports, medication/
prescription records, nurse's notes, doctor's comments, dietary restrictions,
and all patient consent or refusal of treatment, procedures, test, ;and/or
medication, lab and diagnostic test results, including any and all such items
as may be stored in a computer database or otherwise in electronic form,
relating to any examination, consultation, diagnosis, care, treatment,
admission, discharge, or emergency care pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571364 0 7 3 2 G -L 3-S
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573174 0-732G -L 1 6
PENN:3 YLVAN 2 A
COMMONWEALTH (D17
COUNTY OF CLTM13E72LAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- - CASE NO: 04-5572
BORDICK, ET AL
TO
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0-7:326-C!0.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAT. MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS 6i XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0-7:3249-(--C).2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE: 4009.22
TO: Custodian of Records for GETTYSBURG 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: ? LA) o2 /?IQ /5
Seal of the Court
BY THE COURT:
P'4-'fA la=2 2. Z
Prothonotary/Clerk, Civil Divisio
Deputy
07326-16
EXPLANATION OF REQUIRED :RECORDS
TO: CUSTODIAN OF RECORDS FOR:
GETTYSBURG HOSPITAL
147 GETTYS STREET
GETTYSBURG, PA 17325
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Please call for prior approval for fees in excess of $100.00 for hospitals,
$50.00 for all other providers.
Any and all x-ray films and reports, including any and all such items as may
be stored in a computer database or otherwise in electronic form.,
pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, 13A 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
9U10-571366 07326-L aG
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573175 0 7 3 2 6- L a_'7
COT?IONWEALTH OF PENN:SYLVANSA
COUNTY OF CLIMB E]E2LAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
21
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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 ;tour expense by completing
the attached counsel card and returning same to MCS or by contacting our local
MCS office.
DATE: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0'7326-(--02-
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CIE.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAT. MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MHICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & )[RAYS
DE02-305013 0-7:326-C702-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. _ _04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records for ORTHOPEDIC INSTITUTE OF PA.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Group- Inc., 1601 Market Street- Suit 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
BY THE COURT:
Prothonotary/Clerk, Civil
Date: / .c ( 'JI05& 5 Deputy
Seal of the Court
07326-17
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
ORTHOPEDIC INSTITUTE OF PA.
875 POPLAR CHURCH ROAD
CAMP HILL, PA 17011
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic :form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SIJ10-571368 0 7 3 26 -L a_-7
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF:
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
COURT OF COMMON PLEAS
TERM,
CASE NO: 04-5572
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573176 07326-L 3_8
PENNS YLVAN 2 A
COMMONWEALTH (DE,
COUNTY O F CUMB E:RLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0-7:32G-(--0:2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORX HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAT. MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & )RAYS
DE02-305013 0-7-32G-(--0.2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS CIR THINGS
FOR DISCOVERY PURSUANT TO RULE: 4009.22
TO: Custodian of Records for MAGNETIC IMAGING 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 M 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: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: JL D /S6s
Seal of the Court
BY THE COURT:
Prothonotary/Clerk, Civil Divis'
L ?¢
Deputy
07326-18
COMMONWEALTH O F PENNS YLVAN = A
COUNTY O F CUMBERLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-VS- CASE NO: 04-5572
BORDICK, ET AL
21
( Note: see enclosed list of locations )
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0 7 3 2 6- C 0 2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GETTYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS li, XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
DE02-305013 0 7 3 2 G- C 0 2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
vs.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE; 4009.22
TO: Custodian of Records for MOFFITT HEART & VASCULAR GROUP
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following
documents or things: **** SEE ATTACHED RIDER ****
at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103
You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together
with the certificate of compliance, to the party making this request at the address listed above. You have the right
to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,
the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: CASEY SHORE. ESO.
ADDRESS: 2411 N. FRONT ST.
HARRISBURG. PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: J t-'oE, z -2'66?S
Seal of the Court
BY THE COURT:
Protho(noottarry/Clerk, Civil Divisi
eD puty
07326-19
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
MOFFITT HEART & VASCULAR GROUP
1000 N. FRONT STREET
WORMLEYSBURG, PA 17043
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not lirnited to
any and all records, correspondence to and from the consulting and/or treating
physicians, files, memoranda, handwritten notes, history and physical reports,
medication/prescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571372 O 7 3 2 G- L a_.9
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE) TERM,
-v5- CASE NO: 04-5572
BORDICK, ET AL
As a prerequisite to service of a subpoena for documents and things pursuant
to Rule 4009.22
MCS on behalf of CASEY SHORE, 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: 07/18/2005 CASEY SHORE, ESQ.
Attorney for DEFENDANT
DE11-573178 07326--T,20
COMMONWEALTH O F P ENN,S YLVAN 2A
COUNTY O F CUMS E:RLAND
IN THE MATTER OF: COURT OF COMMON PLEAS
SAMANTHA FISHER (BISSONNETTE)
-VS-
BORDICK, ET AL
TERM,
CASE NO: 04-5572
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
[ Note: see enclosed list of locations ]
TO: DAVID B. KLINE, ESQ., PLAINTIFF COUNSEL
MCS on behalf of CASEY SHORE, 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: 06/28/2005
CC: CASEY SHORE, ESQ. - 05-015
PATRICIA HOFFMAN -
MCS on behalf of
CASEY SHORE, ESQ.
Attorney for DEFENDANT
Any questions regarding this matter, contact THE MCS GROUP INC.
1601 MARKET STREET
#800
PHILADELPHIA, PA 19103
(215) 246-0900
DE02-305013 0'732G-C70.2
>>> LOCATION LIST <<<
PAGE: 1
LOCATION NAME RECORDS REQUESTED
HANOVER GENERAL HOSPITAL
HANOVER GENERAL HOSPITAL
GETTYSBURG CHIROPRACTIC CTR.
MRI OF YORK
NATIONWIDE INSURANCE COMPANY
TRISTAN ASSOCIATES
APPLE HILL VASCULAR ASSOC.,LTD
YORK HOSPITAL
YORK HOSPITAL
HOLY SPIRIT HOSPITAL
HOLY SPIRIT HOSPITAL
CROSS KEYS INTERNAL MEDICINE
YORK NEUROSURGICAL ASSOCIATES
SPIRIT PHYSICIANS SERVICES,INC
GE'ITYSBURG HOSPITAL
GETTYSBURG HOSPITAL
ORTHOPEDIC INSTITUTE OF PA.
MAGNETIC IMAGING CENTER
MOFFITT HEART & VASCULAR GROUP
HEALTHSOUTH REHAB
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS & XRAYS
INSURANCE
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS Sr XRAYS
OTHER
OTHER
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS Sr XRAYS
MEDICAL RECORDS & XRAYS
MEDICAL RECORDS F. XRAYS
MEDICAL RECORDS
X-RAY ONLY
MEDICAL RECORDS IF XRAYS
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS ? XRAYS
MEDICAL RECORDS 9, XRAYS
:DE02-305013 0'732G-(--C).2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SAMANTHA FISHER (BISSONNETTE)
VS.
BORDICK, ET AL
File No. 04-5572
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE; 4009.22
TO: Custodian of Records for HEALTHSOUTH REHAB
(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 900. Philadelphia. PA 191173
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: CASEY SHORE. ESO.
ADDRESS: 2411 N FRONT ST
HARRISBURG, PA 17110
TELEPHONE: (215) 246-0900
SUPREME COURT ID #:
ATTORNEY FOR: Defendant
Date: A LLa--? £. a ? ??
Seal of the Court
BY THE COURT:
Prothonotary/Clerk,
Deputy
07326-20
EXPLANATION OF REQUIRED RECORDS
TO: CUSTODIAN OF RECORDS FOR:
HEALTHSOUTH REHAB
175 LANCASTER BLVD
P.O. BOX 2016
MECHANICSBURG, PA 17055
RE: 7326
SAMANTHA FISHER (BISSONNETTE)
Prior approval is required for fees in excess of $100.00 for
hospitals, $50.00 for all other providers.
Entire medical, billing, and diagnostic file, including but not limited to
any and all records, correspondence to and from the consulting and/or treating
physicians; files, memoranda, handwritten notes, history and physical reports,
medicatioJVprescription records, medical billing and payment records, x-ray
films and tests with subsequent reports, including any and all such items as
may be stored in a computer database or otherwise in electronic form, relating
to any examination, consultation, diagnosis, care or treatment pertaining to:
Dates Requested: up to and including the present.
Subject : SAMANTHA FISHER (BISSONNETTE)
4820 OLD HARRISBURG RD., GETTYSBURG, PA 17325
Social Security #: 162-68-3272
Date of Birth: 05-16-1979
SU10-571374 07326-L20
-
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?
,
- ?,
, -,?,
? r ?'
,
<?
r?
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--
_
G
._y V•
.i.
VILLARI, BRANDES & KLINE, PC
BY: Richard M. Wiener, Esquire
Attorney ID No. 68041
Eight Tower Bridge, Suite 400
161 Washington Street
Conshohocken, PA 19428
(610) 729-2900
SAMANTHA M. BISSONNETTE
Attorney for Plaintiffs
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 04-5572 Civil Term
CIVIL ACTION -LAW
VS.
JOSHUA BORDICK
and
TARA L. REINHOLD
JURY TRIAL DEMANDED
PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER
Plaintiff by and through her undersigned counsel, hereby replies to Defendants'
New Matter and avers as follows.
19. This paragraph requires no response.
20. Denies pursuant to Pa. R.C.P. 1029 (e).
WHEREFORE, Plaintiff respectfully request that Defendants' New Matter be
denied and/ or dismissed, and that judgment be entered in Plaintiff's favor.
VILLARI,
BY:
& KLINE
D M. WIENER, ESQUIRE
for Plaintiff
r-' ?
?""' -n
-
- r? ?t
_..; t t:_
_ =''
.?"-
;,,
= ? s
?? r"'•
? -4
+.??
N i
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, H/W,
Plaintiffs
vs.
JOSHUA BORDICK and TARA
REINHOLD,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-5572 Civil Term
JURY TRIAL DEMANDED
CIVIL ACTION - LAW
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
TO THE PROTHONOTARY:
Please withdraw NEALON GOVER & PERRY'S appearance on behalf of the
Defendants, Joshua Bordick and Tara Reinhold, with regard to the above-captioned
matter.
Respectfully submitted,
Date: r? Lo
NEALON,
By:
James G. Nealon III, Esquire
I.D. #: 46457
2411 North Front Street
Harrisburg, PA 17110
717/232-9900
CERTIFICATE OF SERVICE
A 007
AND NOW, this 3"' day o€-Getober, FYI hereby certify that I have served
the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true
and correct copy of same in the United States mail, postage prepaid, addressed to:
David B. Kline, Esquire
Villari, Brandes & Kline, P.C.
8 Tower Bridge, 4th Floor
161 Washington Street
Conshohocken, PA 19428
James G. Nealon III, Esquire
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE, h/w,
Plaintiffs
V.
JOSHUA BORDICK and
TARA L. REINHOLD,
Defendants
NO. 04-5572 CIVIL TERM
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO PA.R.C.P. 1012
TO THE PROTHONOTARY:
Kindly enter the appearance of Michael B. Scheib, Esquire, of Griffith, Strickler, Lerman,
Solymos & Calkins, as attorney for the Defendants, Joshua Bordick and Tara Reinhold, in the
above-captioned matter and mark the docket accordingly.
GRIFFITH, STRICKLER, LERMAN,
SOLYMOS & CALKINS
Date: March 5, 2008
By: )?e U1
MICHAEL B. SCHEIB, ESQUIRE
Supreme Court I.D. No. 63868
110 South Northern Way
York, PA 17402-3737
(717) 757-7602
Attorney for Defendants,
Joshua Bordick and Tara Reinhold
It
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN BISSONNETTE and
SAMANTHA M. BISSONNETTE,
Plaintiffs
NO. 04-5572 CIVIL TERM
V.
JOSHUA BORDICK and
TARA L. REINHOLD,
Defendants
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW, this 5"' day of March, 2008, I, Michael B. Scheib, Esquire, a member of the
firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date
served a copy of.the Praecipe for Entry of Appearance Pursuant to Pa. R.C.P. 1012, by United
States Mail, postage prepaid, addressed to the party or attorney of record as follows:
David B. Kline, Esquire
Villari, Brandes & Kline, P.C.
Eight Tower Bridge
161 Washington Street, Suite 400
Conshohocken, PA 19428
Attorney for Plaintiffs)
GRIFFITH, STRICKLER, LERMAN,
SOLYMOS & CALKINS
By:
MICHAEL B. SCHEIB, ESQUIRE
Supreme Court I.D. No. 63868
110 South Northern Way
York, PA 17402-3737
(717) 757-7602
Attorney for Defendants,
Joshua Bordick and Tara L. Reinhold
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VILLARI, BRANDES & KLINE, P.C. ~ ~ ~ ~ ~
BY: RICHARD M. WIENER, ESQUIRE
sr
IdentificationNo. 68041 ~~f~(.q~~~ ~~~~.~T•:,,
8 Tower Bridge, Suite 400 P'_'NNSYLVp,NIA
161 Washington Street
Conshohocken, PA 19428
(610) 729-2900 Attorney for Plaintiffs
KEVIN BISSONNETTE and : 1N THE COURT OF COMMON PLEAS
SAMANTHA BISSONNETTE, H/W : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiffs :
: CIVIL ACTION - LAW
vs. :
: N0.04-5572
JOSHUA BORDICK :
and :
TARA L. REINHOLD :
Defendants :
STATEMENT OF INTENTION TO PROCEED
To the Prothonotary:
Plaintiffs, Kevin Bissonnette and Samantha Bissonnette, intend to proceed with the
above-captioned matter.
Respectfully submitted,
ILLARI, BRANDES KLINE, P.C.
DATE: CB Y:
ICH RD M. WIENER, ESQUIRE
ttorney for Plaintiffs
~
Y
CERTIFICATE OF SERVICE
I, Richard M. Wiener, Esquire, hereby certify that on this 20`" day of October, 2011, a
true and correct copy of the foregoing Statement of Intention to Proceed was sent via first class
mail, postage pre-paid, to the below-named unrepresented party:
John C. Porter, Esq.
Griffith, Strickler, Lerman, Solymos & Calkins
110 S. Northern Way
York, PA 17402-3737
DATED: 0 ; I (
1IARD M. WIENER, ESQUIRE
fication No. 68041
8 Tower Bridge, Suite 400
161 Washington Street
Conshohocken, PA 19428
(610) 729-2900
Attorney for Plaintiffs
I
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VILLARI, BRANDES & GIANNONE, P.C.
BY: RICHARD M. WIENER, ESQUIRE 2013 MAR 20 �
Identification No. 68041 . 06
8 Tower Bridge, Suite 400 '"""F RL A NL) CO
161 Washington Street 11EASY'LVA° AN`TY
Conshohocken, PA 19428
(610) 729-2900 Attorney for Plaintiffs
KEVIN BISSONNETTE and IN THE COURT OF COMMON PLEAS
SAMANTHA BISSONNETTE, H/W OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiffs
CIVIL ACTION - LAW
VS.
NO. 04-5572
JOSHUA BORDICK
and
TARA L. REINHOLD
Defendants
PRAECIPE TO SETTLE,DISCONTINUE AND END
To the Prothonotary:
Kindly mark this matter settled, discontinued and ended.
VILL;RIHA DES & GIANNONE, P.C.
B
M. WIENER, ESQUI RE
r Plaintiffs