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HomeMy WebLinkAbout13-1807 Supreme Co Y nns lvania Con leas For ProftoaWmy Use tom: F Docket No: CU County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required bylaw or rules of court. " Commencement of Action: Complaint O Writ of Summons O Petition © Transfer from Another Jurisdiction O Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: KRISTA GROSS MINNIE E. ROWE Are money damages requested? M Yes O No Dollar Amount Requested: Owithin arbitration limits (check one) ®outside arbitration limits Is this a Class Action Suit? O Yes M No Is this an MDJAppeal? ® Yes M No Name of Plaintiff /Appellant's Attorney: REGINA M. MCILVAINE, ESQUIRE ® Check here if you have no attorney (are a Self- Represented (Pro Sej Litigant) 1t. Place an «X" to the left of the case c4egory that most acc y d bes your .r MAURY CASE. If you are nu ing mare than one type of claim„ dmock the one that you consider most imps cd. _ TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS O Intentional O Buyer Plaintiff Administrative Agencies O Malicious Prosecution O Debt Collection: Credit Card Ox Motor Vehicle O Debt Collection: Other O Board of Assessment O Board of Elections 3 O Nuisance Dept. of Transportation O Premises Liability ® Statutory Appeal: Other O Product Liability (does not include mass tort) O Employment Dispute: O Slander/Libel/ Defamation Discrimination O Other: O Employment Dispute: Other O Zoning Board O Other: MASS TORT O Other: : O Asbestos O Tobacco O Toxic Tort - DES O Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS O Toxic Waste [3 Other: O Ejectment O Common Law /Statutory Arbitration O Eminent Domain/Condemnation O Declaratory Judgment O Ground Rent 8 Mandamus O Landlord/Tenant Dispute Non - Domestic Relations PROFESSIONAL LIABLITY O Mortgage Foreclosure: Residential Restraining Order O Mortgage Foreclosure: Commercial O Quo Warranto O Dental O Partition © Replevin O Legal O Quiet Title 13 Other: O Medical ©Other: 0 Other Professional: Updated 1 /112011 LOWENTHAL & ABRAMS, P.C. REGINA M. MCILVAINE, ESQUIRE THERIS NOT AN ARBITRATION CASE Identification No. 57673 ASSESSMENT OF DAMAGES 555 City Line Avenue HEARING IS REQUIRED Suite 500 JURY TRIAL DEMANDED Bala Cynwyd, PA 19004 (610) 667 -7511 Attorney for Plaintiff KRISTA GROSS COURT OF COMMON PLEAS 38 Montsera Road CUMBERLAND COUNTY Carlisle, PA 17015 V. NO. MINNIE E. ROWS « 165 Youngs Church Road n 'n Shermansdale, PA 17080 r and o COUNTY OF CUMBERLAND �, o 1 Court House Square _r'u Carlisle, PA 17013 > a w 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 (20) days after the Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed or any other claim or relief requested by the plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THERPAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THEROFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THEROFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELLEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland Countv Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717 -249 -3166 Fax: 717 -249 -2663 Toll Free (in PA): 1- 800 -990 -9108 s at 4'7 r,w � i? F �3g LOWENTHAL & ABRAMS, P.C. REGINA M. MCILVAINE, ESQUIRE THERIS NOT AN ARBITRATION CASE Identification No. 57673 ASSESSMENT OF DAMAGES 555 City Line Avenue HEARING IS REQUIRED Suite 500 JURY TRIAL DEMANDED Bala Cynwyd, PA 19004 (610) 667 -7511 Attorney for Plaintiff KRISTA GROSS COURT OF COMMON PLEAS 38 Montsera Road CUMBERLAND COUNTY Carlisle, PA 17015 : V. NO. MINNIE E. ROWE 165 Youngs Church Road : Shermansdale, PA 17090 and COUNTY OF CUMBERLAND 1 Court House Square ; Carlisle, PA 17013 Plaintiff, by and through her undersigned counsel and in support of her Complaint alleges the following: COMPLAINT 1. Plaintiff, Krista Gross, is an adult individual residing at the above - referenced address. 2. Defendant, Minnie E. Rowe, is an adult individual residing at the above - captioned address. 3. Defendant, County of Cumberland, is a political subdivision, local agency and/or municipal corporation of the Commonwealth of Pennsylvania located in Cumberland County, with an office for acceptance of service at 1 Courthouse Square, Carlisle, PA 17013. 4. At all times relevant herein, Plaintiff, Krista Gross, was the owner and operator of a bicycle. 5. At all times relevant herein, Defendant, Minnie E. Rowe, was the operator of a 2000 Ford E450. 6. At all times relevant herein, Defendant, County of Cumberland, was the owner of the 2000 Ford E450 which was being operated by its agent, servant, employee and/or workman, Minnie E. Rowe. 7. On May 16, 2011 the bicycle operated by Plaintiff, Krista Gross, was lawfully stopped for a red light on Westminster Drive at its intersection with Army Heritage Drive with Defendant's vehicle behind her. When the light turned green Plaintiff proceeded forward into the intersection but was struck by the vehicle being operated by Defendant Rowe as Defendant R Rowe attempted to pass Plaintiff on the left while making a right turn onto Army Heritage Drive. 8. On May 16, 2011, the vehicle owned by Defendant, County of Cumberland, and being operated by Defendant, Minnie E. Rowe, was traveling behind Plaintiffs bicycle on Westminster Drive. When the light turned green and Plaintiff proceeded forward Defendant attempted to pass Plaintiff on the left while making a right turn onto Army Heritage Drive and into the path of Plaintiff, causing numerous personal injuries to Plaintiff, more specifically set forth herein. COUNT PLAINTIFF. KRISTA GROSS V. NUNNIE E ROWE, DEFENDANT NEGLIGENCE 9. Plaintiff incorporates herein by reference each and every averment contained in paragraphs 1 through 8 as though the same were set forth fully herein at length. 10. At times relevant hereto, the negligence and carelessness of the Defendant consisted of inter alia: a. Failing to have her motor vehicle under proper and reasonable control at all relevant times herein; b. Operating her motor vehicle in such a manner as to cause it to collide into and against Plaintiffs bicycle; C. Failing to give prompt, proper, and adequate warning of her approach; d. Operating her motor vehicle without due regard to the presence, rights and safety of the Plaintiff; e. Failing to keep a proper lookout; f. Violating the various ordinances and laws of Cumberland County and the statutes of the Commonwealth of PA pertaining to the operation and control of motor vehicles, including but not limited to 75 Pa. C.S.A. 3361- driving vehicle at safe speed; g. Being inattentive; h. Failing to operate her motor vehicle in a safe and proper manner; i. Failing to timely and appropriately apply the brakes of her vehicle or to take such other measures as were necessary to avoid the above - described collision; j. Failing to comply with the laws, rules and regulations of the PA Motor Vehicle Code pertaining to the operation of motor vehicles on or about the public highways; k. Failing to give full time and attention to the operation of her motor vehicle; 1. Operating her motor vehicle at a high and excessive rate of speed under the circumstances; m. Failing to avoid colliding with Plaintiff's motor bicycle. 11. As a direct and proximate result of Defendant's negligence, Plaintiff, Krista Gross, suffered various injuries including but not limited to: post traumatic headaches; closed head injury; post concussive syndrome; vestibular dysfunction; speech dysfunction; left face weakness; cervical, thoracic, lumbar and shoulder sprain and strain; cervicobrachial syndrome; cervicocranial syndrome; limited shoulder range of motion; shoulder pain; thoracic neuritis; thoracic pain; myofascitis; muscle spasm; upper lumb joint dysfunction; low back pain; sacroiliac pain; pelvic and leg pain; muscle weakness; joint stiffness; subluxations; RSD; severe and permanent shock to her nerves and nervous system; as well as various other injuries and conditions that may be established, all of which have caused her and will continue to cause her great physical pain and suffering and anxiety, and have prevented her and will continue to present her from attending to her daily activities and occupation, all to her great financial detriment and loss. 12. As a direct and proximate result of Defendant's negligence, Plaintiff, Krista Gross, has incurred and will in the future incur economic losses including medical expenses for the diagnosis, treatment and rehabilitation of her injuries. 13. As a direct and proximate result of Defendant's negligence, Plaintiff, Krista Gross, has in the past suffered and may in the future suffer mental and emotional distress, humiliation, embarrassment, agitation and nervousness. 14. As a direct and proximate result of Defendant's negligence, Plaintiff, Krista Gross, has in the past suffered and may continue in the future to suffer great physical and mental pain and suffering. 15. As a direct and proximate result of Defendant's negligence, Plaintiff, Krista Gross, has incurred expenses for property damage. 16. As a direct and proximate result of Defendant's negligence, Plaintiff, Krista Gross, has suffered and will in the future suffer a loss of earnings and impairment of earning capacity and potential. 17. As a direct result and proximate result of Defendant's negligence, Plaintiff, Krista Gross, has in the past suffered and may in the future suffer from the inability to live a normal life and enjoy life's pleasures, including but not limited to an inability to attend to her usual daily duties and activities. WHEREFORE, Plaintiff demand judgment and damages against Defendant in an amount in excess of Fifty Thousand Dollars ($50,000.00) plus interest and costs and such other relief as therHonorable Court deems just and appropriate. COUNT II PLAINTIFF, KRISTA GROSS, V. DEFENDANT, COUNTY OF CUMBERLAND NEGLIGENCE 18. Plaintiff incorporates by reference the allegations in paragraph 1 through 17 as though the same were fully set forth herein at length. 19. The negligence of Defendant, County of Cumberland, consisted of the following: a. The Defendant entrusted its vehicle to Defendant, Minnie E. Rowe, when it knew or should have known that she was a substandard, unsafe driver or an inexperienced driver, unfamiliar with Defendant's vehicle; b. The Defendant negligently disregarded the risk to bicyclists by allowing Defendant, Minnie E. Rowe, to operate a vehicle upon the highway or roadway in the fashion she did, without keeping a proper lookout, among others, thus causing the accident; and, C. The Defendant knew or should have known that it was unsafe for its vehicle to be on the roadway and thus negligently disregarded the dangerous risk to bicyclists by allowing Defendant, Minnie E. Rowe, to operate the vehicle without assuring her to drive safely and hereby caused the injuries herein described. 19. Defendant, Minnie E. Rowe, was an agent, servant, employee and/or workman of Defendant, County of Cumberland, and as such, County of Cumberland is liable to Plaintiff for the negligence of its agent, servant, employee and/or workman under the Doctrine of Respondeat Superior. WHEREFORE, Plaintiff demand judgments against the Defendants in an amount of damages in excess of FIFTY THOUSAND DOLLARS ($50,000.00) in compensatory damages, together with interest, costs, attorneys' fees and such other awards as the Court deems appropriate. LOWENTHAL & ABRAMS, P.C. By: I AM. MCILVA E, ESQUIRE DATED: �, T Attorney for Plaintiff �. VERIFICATION I, REGINA M. MCILVAINE, ESQUIRE, depose and say that I am an attorney -at -law in the offices of Lowenthal & Abrams, P.C.; that I am authorized to make this Verification; and, that the facts set forth in the foregoing Plaintiff's Complaint are true and correct to the best of my knowledge, information and belief. This statement is made subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsification to authorities. ' JIA M. MCILVAINE, ESQUIRE Attorney for Plaintiff DATE• �%�����U��"�% ����U/��� ��� CUMBERLAND� COUNTY ��"SHERIFF'S�� ��" " "��~� ��" Ronny RAnderson n FF1C Sheriff OF- N�T PAMTHON0_TAR`/ Jody SSmith Chief Deputy 2m13APR 29 AM ,T 33 Richard VVStewart ` «� ' --' CUMBERLAND Ty Solicitor ~ WS /UVAN|A KhsteGross Case Number vs. 2013-1807 Minnie E Rowe (et al.) � SHERIFF'S RETURN OF SERVICE 0409/2013 Sheriff Ronny R Andermzn, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant tnwit: Minnie E Rowe, but was unable to locate the Defendant in the Sheriff's bailiwick. The Sheriff therefore deputizes the Sheriff of Perry, Pennsylvania to serve the within Complaint& Notice according to law. 04/11/2013 04:20 PM- Sheriff Ronny R. Anderson,.being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Commissioner Barbara Cross, who accepted as"Adult Person in Charge"for County of Cumberland at 1 Courthouse Square, Car|io|e, PA 17013. _.� 'ANDERSON, SHERIFF — 04/15/2013 02:10 PM -The requested Complaint& Notice served by the Sheriff of Perry County upon Minnie E Rowe, personally, at 165 Young Church Road, Shermansdale, PA 17080. Carl E. Nace, Sheriff, Return of Service attached to and mode part of the within record. SHERIFF COST: s53.OU SO ANSWERS, April 17. 2U13 MONNYM ANDERSON, SHERIFF wCoumySuiwShoritf,mleosoft,Inc. Krista Gross IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Versus Minnie E. Rowe No. 2013-1807 Cumberland Co. SHERIFF'S RETURN And now April 15 , 2013 : Served the within name Minnie E. Rowe the defendant(s) named herin, personally at her place of residence in Carroll Twp-165 Youngs Church Rd., Shermans Dale, Perry County, PA, on April 15, 2013 at 2:10 o'clock PM by handing to Minnie E. Rowe, defendant 1 true and attested copy(ies) of the within Writ of Summons and made known to her the contents thereof Sworn and subscribed to before me this day of ,oZ(�/ 3 So answers �e De t Sheriff Perry County COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F.FLICKINGER,Notary Public Bloomfield Boro,Perry County My commission Expires February 16,2016 1) WILLIAM J. FERREN &ASSOCIATES 04 x PIE PAR' �E Rt?Tf OP40TAP; BY: Leticia J. Santiago, Esquire Attorney ID# 308519 � J —� P 10 Sentry Parkway H 2 03 Suite 301 ^UMBERLANO COUNT'?` Blue Bell, PA 19422 PENNS (610) 274-1724 Attorney o A dants Minnie E. Rowe and County of Cumberland KRISTA GROSS COURT OF COMMON PLEAS V. CUMBERLAND COUNTY MINNIE E. ROWE and COUNTY OF NO.: 13-1807 CUMBERLAND JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendants, Minnie E. Rowe and County of Cumberland regarding the above-captioned matter. Kindly demand a jury of(12)regarding the above defendants. WILLI J. FERREN& ASSOCIATES BY: Leticia J. Santiago, Esquire Attorney for Defendants WILLIAM J. FERREN & ASSOCIATES BY: Leticia J. Santiago, Esquire Attorney ID# 308519 10 Sentry Parkway Suite 301 Blue Bell, PA 19422 Attorney for Defendants (610) 274-1724 Minnie E. Rowe and County of Cumberland KRISTA GROSS COURT OF COMMON PLEAS CUMBERLAND COUNTY V. NO.: 13-1807 MINNIE E. ROWE and COUNTY OF CUMBERLAND JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Leticia J. Santiago, Esquire, counsel for Defendants, Minnie E. Rowe and County of Cumber hereby state that a true and correct copy of the foregoing Entry of Appearance was served on the parties listed below on April 30 ,2013 by U.S. First Class Mail, Postage Pre-Paid to the following. Regina M. Mcilvaine, Esquire LOWENTHAL &ABRAMS, P.C. 555 City Line Avenue Suite 500 Bala Cynwyd, PA 19004 WILLIA J. FERREN & ASSOCIATES BY: Leticia J. Santi Esquire Attorney for D endants CD LOWENTHAL & ABRAMS, P.C. ,-�, rnij= By: Regina M. McIlvaine, Esquire Attorney Identification No. 57673 Y `< 555 City Line Avenue, Suite 500 Bala Cynwyd, PA 19004 C_ ``F C-) : (610) 667-7511 Attorneys for Plaintiff a KRISTA GROSS COURT OF COMMON PLEAS CUMBERLAND COUNTY V. MINNIE E. RO WE and COUNTY OF CUMBERLAND NO. PRAECIPE TO SUBSTITUE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification of Plaintiff, Krista Gross, for that of her counsel, Regina M. McIlvaine, Esquire, in connection with Plaintiff s Complaint filed in the above-captioned matter. LOWENTHAL & ABRAMS,P.C. r n� BY: `` Or RE)(, !*A M. MCILVAINE,ESQUIRE DATE:.A �� 14;.08.2012 08:56 PM THE GEDAS 7177909895 PAGE. 2/ 2 VERIFICATION 1, KRISTA GROSS, hereby verify that I am the Plaintiff in the within action; that the ^ ~facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief;and that these statements are made subject to the penalties of 18 Pa-C.S. §4904,relating to unsworn falsification to authorities. KRt S A GR S DATED: THE PROT1 014 rTAIR TO:PLAINTIFF YOU ARE HEREBY NOTIFIED JUL 1 i 11; �(} TO PLEAD TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM CUMBERLAND c0UHTY THE SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST jY eticia J. Santiago uire WILLIAM J. FERREN &ASSOCIATES BY: Leticia J. Santiago, Esquire Attorney ID#308519 10 Sentry Parkway Suite 301 Blue Bell,PA 19422 Attorney for Defendants (610) 274-1724 Minnie E. Rowe and County of Cumberland KRISTA GROSS COURT OF COMMON PLEAS CUMBERLAND COUNTY V. NO.: 13-1807 MINNIE E. ROWE and COUNTY OF , CUMBERLAND JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANTS MINNIE E. ROWE AND COUNTY OF CUMBERLAND TO PLAINTIFF'S COMPLAINT 1. . Denied. After reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 1. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. 2. Admit. 3. Denied as stated. Defendant County of Cumberland is a county, a political and geographic subdivision of the Commonwealth of Pennsylvania, with a business address of 1 Courthouse Square, Carlisle, PA 17013. 4. Admit that plaintiff was operating a bicycle on May 16, 2011 in the vicinity of Westminster Drive and Army Heritage Drive in the County of Cumberland. Denied that plaintiff was the owner of the bicycle. After reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of whether plaintiff owned the bicycle. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. 5. Admit. 6. Denied as stated. Admit that defendant County of Cumberland owned the 2000 Ford E450 on May 16,2011 and that defendant Rowe operated the vehicle. 7. Denied. After reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 7. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. 8. Denied. After reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 8. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. COUNT PLAINTIFF, KRISTA GROSS V. MINNIE E. ROWE,DEFENDANT NEGLIGENCE 9. Answering defendants incorporate herein their responses to paragraphs 1 through 8, inclusive as if set forth verbatim. 10. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 10. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, each and every subpart of this paragraph is specifically denied in that answering defendants neither acted nor failed to act as averred but rather conducted their activities, if any, with due care and caution. Answering defendants deny all claims of negligence and carelessness. 11. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 11. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants neither acted nor failed to act as averred but rather conducted their activities, if any, with due care and caution. Answering defendants deny all claims of negligence. 12. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the. averments of paragraph 12. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants deny all claims of negligence. 13. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 13. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants deny all claims of negligence. 14. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 14. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants deny all claims of negligence. 15. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 15. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants deny all claims of negligence. 16. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 16. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants deny all claims of negligence. 17. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 17. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants deny all claims of negligence. WHEREFORE, answering defendants demand judgment be entered in their favor and against plaintiff. COUNT II PLAINTIFF, KRISTA GROSS V. DEFENDANT, COUNTY OF CUMBERLAND NEGLIGENCE 18. Answering defendants incorporate herein their responses to paragraphs 1 through 8, inclusive as if set forth verbatim. 19. Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of paragraph 19. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, each and every subpart of this paragraph is specifically denied in that answering defendants neither acted nor failed to act as averred but rather conducted their activities, if any, with due care and caution. Answering defendants deny all claims of negligence. 20. 'Denied as a conclusion of law to which no further response is required under the Pennsylvania Rules of Civil Procedure. To the extent that there are any factual averments in this paragraph, they are denied in that after reasonable investigation, answering defendants are without sufficient knowledge or information to form any belief as to the truth or falsity of the averments of the second paragraph 19. Therefore, they are deemed denied and strict proof thereof is demanded at the trial of this cause, if material or relevant. Further, answering defendants neither acted nor failed to act as averred but rather conducted their activities, if any, with due care and caution. Answering defendants deny all claims of negligence. Answering defendants admit that defendant Rowe was employed by the County of Cumberland on May 16, 2011. WHEREFORE, answering defendants demand judgment be entered in their favor and against plaintiff. NEW MATTER DIRECTED TO PLAINTIFF 21. Plaintiff's claims are barred or limited by the applicable Statute of Limitations. 22. Plaintiff fails to state a claim upon which relief may be granted. 23. Plaintiff's injuries, if any, were not factually caused by any acts or omissions on the part of answering defendant. 24. Plaintiff has failed to mitigate her alleged damages. 'The complaint is misnumbered and contains two paragraph 19. 25. The negligent acts and/or omissions of other individuals and/or entities may have constituted an intervening, superceding cause of the damages alleged to have been sustained by the plaintiff. 26. If plaintiff suffered injuries or damages as alleged, which averments are denied, than the sole and exclusive cause of any such alleged injuries or damages was the negligence and carelessness of others and not that of answering defendant. 27. Plaintiff's claims are barred by res judicata. 28. Plaintiffs claims are barred by collateral estoppel and the doctrine of release. 29. Plaintiff's claims are barred by the Political Subdivision Tort Claims Act. 30. Plaintiff's claims may be barred in whole or in part by the applicable provisions of the Pennsylvania Financial Responsibility Law. 31. Answering defendant incorporates herein all defenses set forth in Pa. RCP Rule 1030. WHEREFORE, answering defendants demand judgment be entered in their favor and against plaintiff. WILL M J. FERREN& ASSOCIATES BY• Ieticia J. Santiago,ts4uire Attorney for Defendants Dated: July 52013 VERIFICATION I, Minnie E. Rowe, am a defendant named herein. I have reviewed the foregoing Answer with New Matter of Defendants Minnie E. Rowe and County of Cumberland and the statements contained therein are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Minnie E. Rowe ' Dated: June , 2013 Po j3 1 i i VERIFICATION hereby verify that I am authorized to i take this verification on behalf of Defendant County of Cumberland. I have reviewed the foregoing Answer with New Matter of Defendants Minnie E. Rowe and County of Cumberland and the statements contained therein are true and correct to the best of my knowledge,information and belief. I understand that this Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unworn falsification to authorities. On behalf of Defendant, County of Cumberland . l Dated: July ,2013 l WILLIAM J. FERREN& ASSOCIATES BY: Leticia J. Santiago, Esquire Attorney ID# 308519 10 Sentry Parkway Suite 301 Blue Bell, PA 19422 Attorney for Defendants (610) 274-1724 Minnie E. Rowe and County of Cumberland KRISTA GROSS COURT OF COMMON PLEAS CUMBERLAND COUNTY V. NO.: 13-1807 MINNIE E. ROWE and COUNTY OF CUMBERLAND JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Leticia J. Santiago, Esquire,counsel for Defendants, Minnie E. Rowe and County of Cumber hereby state that a true and correct copy of the foregoing Answer with New Matter was served on the parties listed below on July by U.S. First Class Mail,Postage Pre-Paid to the following. Regina M. Mcilvaine, Esquire LOWENTHAL &ABRAMS, P.C. 555 City Line Avenue Suite 500 Bala Cynwyd, PA 19004 WILLI J. FERREN& ASSOCIATES B Leticia J. Santi Yendants Esquire Attorney for De LOWENTHAL & ABRAMS, P.C. � '�"€7� n `� By: Regina M. McIlvaine, Esquire Attorney Identification No. 57673 /4 P:. 555 City Line Avenue, Suite 500 5 Bala Cynwyd, PA 19004 E'1v 0 c (610) 667-7511 Attorneys for Plaintif&�VAAT ' KRISTA GROSS COURT OF COMMON PLEAS CUMBERLAND COUNTY V. MINNIE E. ROWE and COUNTY OF CUMBERLAND NO. / - 7 PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER 21.-31. Denied. The allegations of these paragraphs are denied both as averments of fact and conclusions of law. WHEREFORE, Plaintiff demands judgment in her favor and against the Defendants. LOWENTHAL & ABRAMS,P.C. BY: i `I A M. CILVAI E, UU�tESQUIRE UIRE DATE: (�J WILLIAM J. FERREN &ASSOCIATES BY: Leticia J. Santiago, Esquire °; 2 0 Attorney ID# 308519 10 Sentry Parkway J ' I 1 %S.- 1`'�' ;�, t IP Suite 301 '� 'i'1SYL�t lily{ Blue Bell, PA 19422 Attorney for Defendants (610) 274-1724 Minnie E. Rowe and County of Cumberland KRISTA GROSS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY v. • NO.: 13-1807 MINNIE E. ROWE and COUNTY OF • CUMBERLAND JURY TRIAL DEMANDED MOTION TO COMPEL PLAINTIFF KRISTA GROSS TO ANSWER DEFENDANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS 1. On January 24, 2014, counsel for Defendants, Minnie E. Rowe and County of Cumberland sent Interrogatories and a Request for Production of Documents to plaintiff's counsel for answer by plaintiff. A copy of defense counsel's letter is attached hereto as Exhibit 2. Under date of March 3, 2014, counsel for Defendants, Minnie E, Rowe and County of Cumberland sent a reminder letter to plaintiff's counsel requesting discovery responses within ten(10) days. A copy of defense counsel's letter is attached hereto as Exhibit «B, 3. Plaintiff, Krista Gross, has failed to respond to said requests within the time frame set by the Pennsylvania Rules of Civil Procedure, nor has he sought a Protective Order. 4. Over thirty(30) days have passed since defendants served their discovery requests and Plaintiff, Krista Gross has yet to respond. 5. Di:.0:ndants, Minnie E. Rowe and County of Cumberland are severely prejudiced__ in the preparation of their defense of this lawsuit by plaintiff's failure to respond to discovery requests. WHEREFORE, Defendants, Minnie E. Rowe and County of Cumberland respectfully request this Honorable Court enter the attached Order compelling plaintiff, Krista Gross to answer Defendants' Interrogatories and Request for Production of Documents within twenty(20) days of the date of the Order. Respectfully submitted, WILLI�% J. FERREN &ASSOCIATES By: eticia J. Santiago, Es"uire Attorney for Defendants Date: March t1 , 2014 WILLIAM J. FERREN &ASSOCIATES — ---- . BY: Leticia J. Santiago, Esquire Attorney ID# 308519 10 Sentry Parkway Suite 301 Blue Bell, PA 19422 Attorney for Defendants (610) 274-1724 Minnie E. Rowe and County of Cumberland • KRISTA GROSS COURT OF COMMON PLEAS • CUMBERLAND COUNTY v. • NO.: 13-1807 MINNIE E. ROWE and COUNTY OF CUMBERLAND JURY TRIAL DEMANDED ATTORNEY CERTIFICATION OF GOOD FAITH The undersigned counsel for movant certifies and attests that: x a. He or she has had the contacts described below with opposing counsel or unrepresented party regarding discovery matter contained in the foregoing discovery motion in an effort to resolve the specific discovery dispute(s) at issue and further,that despite all counsel's good faith attempts to resolve the dispute(s), counsel has been unable to do so. Description: See Exhibit"A"and"B" b. He or she has made good faith but unsuccessful efforts described below to contact opposing counsel or unrepresented party in an effort to resolve the discovery dispute. Description: CE IFIED TO THE COURT BY: Date: � �� 1 /11111111 • it.rney for Movant( A e parry) Note: The Signature of Respondent's Counsel is Not Required WILLIAM J. FERREN & ASSOCIATES BY: Leticia J. Santiago, Esquire Attorney ID# 308519 10 Sentry Parkway Suite 301 Blue Bell, PA 19422 Attorney for Defendants (610) 274-1724 Minnie E. Rowe and County of Cumberland KRISTA GROSS • COURT OF COMMON PLEAS CUMBERLAND COUNTY v. • NO.: 13-1807 MINNIE E. ROWE and COUNTY OF • CUMBERLAND JURY TRIAL DEMANDED • CERTIFICATE OF SERVICE I, Leticia J. Santiago, counsel for Defendants, Minnie E. Rowe and County of Cumberland, hereby state that a true and correct copy of the foregoing Motion to Compel Discovery was served on counsel below on March ('1 ,2014 by U.S. First Class Mail,Postage Prepaid: Regina M. Mcllvaine, Esquire LOWENTHAL &ABRAMS, P.C. 555 City Line Avenue Suite 500 Bala Cynwyd, PA 19004 WILLIA■/ J. FERREN&ASSOCIATES jAft11114, cia J. Santiago E.`':ire Attorney for Defendants V iLRIF1CATION I, Leticia J. Santiago, Esquire, state that I am the attorney for the Defendants, Minnie E. Rowe and County of Cumberland and make this Verification and state that the statements made in the foregoing Motion to Compel Discovery Answers of Defendants are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. am A 1411060 TICIA J. SANTIAG•Jr SQUIRE Date: March 10 , 2014 • EXHIBIT An LAW OFFICES WILLIAM J. FERREN &ASSOCIATES 10 Sentry Parkway, Suite 301 Blue Bell,PA 19422 Phone(215)274-1700 Fax(215)274-1735 Leticia J. Santiago,Esquire Direct Dial(215)274-1724 Email: ljsantia @travelers.com January 24,2014 Regina M. Mcllvaine,Esquire LOWENTHAL&ABRAMS,P.C. 555 City Line Avenue Suite 500 Bala Cynwyd, PA 19004 Re: Krista Gross v. County of Cumberland,et al. Cumberland Cty. CCP,No. 13-1807 Claim No.: EPL0705 Our File No.: 2013025688 Dear Ms. Mcllvaine: I, along with Claim Representative Jeremy Baer,have reached out to you on several occasions to discuss settlement. Unfortunately, you have not returned our calls. We remain interested in discussing settlement with you and are hopeful that you will contact us. Enclosed please find Interrogatories and a Request for Production of Documents addressed to Plaintiff, Krista Gross. Kindly provide your client's responses within the time set forth by the Pennsylvania Rules of Civil Procedure. Finally, I understand that your office has called to schedule depositions. With the expectation that you will timely respond to the within discovery requests, I am available on the following dates: March 25th, 26th, and 27th. Thank you for your attention to this matter. Sincerely yours, -- Leticia J. Santiago LJS:gh cc: Jeremy Baer- CJR (w/o encl.) Mick Burkett(w/o encl.) Minnie Rowe (w/o encl.) Not a Partnership or Professional Corporation All Attorneys are Employees of The Travelers Indemnity Company and its Property Casualty Affiliates and Subsidiaries • EXHIBIT " B" LAW OFFICES WILLIAM J. FERREN &ASSOCIATES 10 Sentry Parkway, Suite 301 Blue Bell,PA 19422 Phone (215)274-1700 Fax(215)274-1735 Leticia J.Santiago,Esquire Direct Dial(215)274-1724 Email:ljsantia@travelers.com January 24,2014 Regina M. Mcllvaine,Esquire LOWENTHAL&ABRAMS,P.C. 555 City Line Avenue Suite 500 Bala Cynwyd, PA 19004 Re: Krista Gross v. County of Cumberland,et al. Cumberland Cty. CCP,No. 13-1807 Claim No.: EPL0705 Our File No.: 2013025688 Dear Ms.Mcllvaine: Please be advised that on January 24, 2014, Defendant's Interrogatories Addressed to Plaintiff and Defendant's Request for Production of Documents directed to Plaintiff were sent to your attention. To date, your client has not provided complete and verified answers to said discovery requests. Please provide your responses within ten (10) days of receipt of this correspondence in order to avoid unnecessary motion practice. Thank you for your attention to this matter. cerely yours, IMP Leticia J. S. t. :o LJS:gh cc: Jeremy Baer-C/R Mick Burkett Minnie Rowe Not a Partnership or Professional Corporation All Attorneys are Employees of The Travelers Indemnity Company and its Property Casualty Affiliates and Subsidiaries KRISTA GROSS V. MINNIE E. ROWE and COUNTY OF CUMBERLAND JURY TRIAL DEMANDED COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 13-1807 AND NOW, this ORDER day of Z4ld4'). , 2014, upon consideration of the Motion of Defendants, Minnie E. Rowe and County of Cumberland to Compel Answers to Discovery, it is hereby ORDERED and DECREED that Plaintiff, Krista Gross shall provide full and complete responses to Defendants' Interrogatories and Request for Production of Documents within twenty (20) days or suffer such sanctions as the Court may deem fit. BY THE COURT: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 14-03053LG In the Matter of: Court of Common Pleas -103 .x- KRISTA NICHOLE GROSS Cumberland County rn� • rr -VS - -< MINNIE E. ROWE AND COUNTY OF No. 13-1807 r' CUMBERLAND • c. -II T C N r As a prerequisite to service of a subpoena for documents and things pursuant to RuIe-4009'.22=W; CCLR on behalf of LETICIA J. SANTIAGO, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s) with a copy of the subpoena(s) attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s) which will be served is/are identical to the subpoena(s) which is/are attached to the notice of intent to serve the subpoena(s). DATE: 5/13/2014 LETICIA J. SANTIAGO, ESQUIRE Counsel for Defendant CLLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com KRISTA NICHOLE GROSS VS. MINNIE E. ROWE AND COUNTY OF No. 13-1807 CUMBERLAND IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS REGINA MCILVAINE, ESQUIRE LOWENTHAL & ABRAMS, P.C. 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 Please take notice there has been a request by LETICIA J. SANTIAGO, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to KRISTA GROSS. Enclosed is(are) a copy (copies) of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: April 22, 2014 Enclosures : Copy (copies) of Subpoena(s) Counsel Return Page Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com KRISTA NICHOLE GROSS vs. MINNIE E. ROWE AND COUNTY OF CUMBERLAND CCLR File NO. 14-03053LG COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 4/22/2014 regarding records in the custody of (see attached subpoena(s)) and respond as follow: (1) COPIES yes / no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) 1 would like copies of X -Rays sent to me. (3) OBJECTION In accordance to rules governing civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions prior to 5/13/2014. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) I would like to look at the records at a Center City location before deciding whether to order a copy. 2014 Copy Fees/Per Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61 & Above $.20 Date: yes / no yes / no Attorney for plaintiff(s) / defendant(s) REGINA MCILVAINE, ESQUIRE LOWENTHAL & ABRAMS, P.C. 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff : File No, 13-1807 VS. : MINNIE E. ROWE AND COUNTY:-: CUMBERLAND Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To:ALLEGANY OPTICAL MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies, of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought, if you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CCR, 1. 1315 Waicnu,re1 St 601 TE :07 SU 01, ti ATTORNEVCO si:W.401-19ANT , • Date: -.J41_ Seal of the tourt. BY THE CO Pro h ary, Civil Division Deputy Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: ALLEGANY OPTICAL - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff vs. MINNIE E. ROWE AND COUNTY OF CUMBERLAND Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-22 TO: APPLE HILL EYE CENTER WILLIAM H. DRUSEDUM, OD (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:LETICIA J.. SANTIAGO, ESQUIRE ADDRESS: TELEPHONE:: SUPREME COLLIJOMU ATTORNEY FO I NT Date: £J ciy Sea! of the'Court BY THE COU Prothonotary, Civil Divi on Deputy „Ask, CLLR • • • • Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: APPLE HILL EYE CENTER - WILLIAM H. DRUSEDUM, OD Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE. GROSS Plaintiff . • VS. MINNIE E. ROWE AND COUNTY OF CUMBERLAND • Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: ASSOCIATED PSYCHOLOGISTS MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. if you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMELETICIA J. SANTIAGO, ESQUIRE ADDRESS: fcy _1tCa ,.. Ste, 601 TELEPHONe:' X07 SUPREME (}OURT ID.#... ATTORNEY FOES:, b5Fi T ANT Date: Sea! of the court t Deputy BY THE COURT Prothon r iv y, ilDivisRon CCLR ■ ■ ■ :■ Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG **************************. ADDENDUM TO SUBPOENA ************************** To: ASSOCIATED PSYCHOLOGISTS - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL PSYCHOLOGICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff . File No. 13-1807 3-1807 VS. MINNIE E. ROWE AND COUNTY OF' CUMBERLAND Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:BOILING SPRINGS FAMILY MEDICINE CHADLER M. JUMPER, MD (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMELETICIA J. SANTIAGO, ESQUIRE ADDRESS: TF EP O.NE: •PIZ'RMECOURT ID # AYT*NEY FORREFINS''. °7 • • Ea Date. - { C1ty Seal of th Court BY THE COUR Prothonotary, ivil Divisi.n Deputy Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: BOILING SPRINGS FAMILY MEDICINE - CHADLER M. JUMPER, MD Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff . VS. MINNIE E. ROWE AND COUNTY OF CUMBERLAND • Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:BRENT G. BINDER, DC MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: te 6�1 S U P IIMa ".I ' ATTORNEY gE)ICi1,?21VRND 13Y THE COURT- Prothonot11 Divisila�n Date: J .,J al aim /(j/ Seal of the tourt Deputy CLLR . • .• Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: BRENT G. BINDER, D.C. - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NIHCOLE GROSS Plaintiff.. MINNIE E. ROW.AND COUNTY OF CUMBERLAND Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CAMPHILL EMERGENCY PHYSICIANS RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. if you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: T-CUTWISIaANTIAGO, ESQUIRE AD QfP. 601 Ph ilade}phia, -9. TEL HON SUPREME 3`' `''i I y "W ATTORNEY FOR: DEFENDANT Date:J-Z/�.ZO!'� Seal, of the t,ourt • BY THE COURT: Protho1� vil Division Deputy CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: CAMP HILL EMERGENCY PHYSICIANS - RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. " CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS PlaintifT . : File No. 13-1807 MINNIE E. ROWES SAND COUNTY OF CUMBERLAND Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To:CARLISLE DERMATOLOGY ASSOCIATES PC MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: TELE'1HONE: 601 SUPREME couRdd 111p,PA 19107 ATTORNEY FO ' :'. yify opir Date: Sea the� Deputy CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: CARLISLE DERMATOLOGY ASSOCIATES PC - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff . , File No. VS. MINNIE R. ROWE AND COUNTY OF CUMBERLAND Defendant 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE DIGESTIVE DISEASE ASSOCIATES MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: TELEPHONE: I1I tEI E COURtS 'eet Ste. 601 ATNJEY FOR.: ft ,-; 97 . -11rc �rl ., Date: Ja4_, ..2% 2O/ Seal cf the Court BY THE COURT: k _ms Prothono'' awe Division Deputy CLLR . • . Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: CARLISLE DIGESTIVE DISEASE ASSOCIATES - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED " (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS P�aintift .: File No. 13-1807 VS. CUMBERLAIJDROWE AND COUNTY OF: Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE NEUROCARE MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail Legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: LETICIA J ,SANTIAGO, ESQUIRE NAME: -, n �¢ ADDRESS: ```—`' :.;'_ :718x . 3 treet, Site. 601 TELEOIVL:LP�Yi@4 SUPREME ATTORNE\FOR: Date: Se& of the i ® Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 • ` • (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: CARLISLE NEUROCARE - MEDICAL RECORDS DEPARTMENT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff File No. 13-1807 VS. MINNIE E. ROWE AND COUNTY OF CUMBERLAND Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** CENTER CITY LEGAL REPRODUCTIONS, INC. at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: fitcANTIAGO, ESQUIRE :i.tf iin it Street; Stc„. 601 Philadelphia. PA 19107 TELEPHOklE& r , of SUPREME4O RT'1•D ' ATTORNEY FOR:DEFENDANT Date ; , yy Seal of the Court Deputy BY THE COU Proth teary, Civil Division Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: CARLISLE REGIONAL MEDICAL CENTER - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff File No. 13-1807 MINNIE E. RuOSWE AND COUNTY' OF CUMBERLAND TO: Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CARLISLE REGIONAL MEDICAL CENTER RADIOLOGY FILE ROOM (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fad 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: NAMELETICIA J. SANTIAGO, ESQUIRE ADDRESS: TELEPHONE: SUPREMEd I•* -1J ATTORNEY FOR:`•DEb'-NJD/INT Date:JA � Seal of the Court BY THE CO Prothono ary, Civil Divi ion Deputy CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: CARLISLE REGIONAL MEDICAL CENTER - RADIOLOGY FILE ROOM Re: KRISTA GROSS ANY AND ALL FILMS, MRI'S, CAT SCANS, X-RAYS, INCLUDING RADIOLOGY REPORTS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff MINNIE E. ROW. AND COUNTY OF CUMBERLAND Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUMBERLAND ORTHOPEDIC ;&SPINE PHYSICAL THERAPY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ***SEE ATTACHED ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it, THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETI:, ESQUIRE ADDRESS: r"•te. 601 PA 19107 TELEPHONE:. SUPREME COURT Mt ATTORNEY FOR: DEFENDANT Date; t 021 2:C_Nty Seal oft{;,.t Court BY THE COU Prot' otary, Civil Divisio Deputy CLLR MEIN. Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: CUMBERLAND ORTHOPEDIC & SPINE PHYSICAL THERAPY - MAUREEN BELTRANDI, PT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff. VS. MINNIE E. ROWE AND COUNTY OF CUMBERLAND Defendant File No. 1 3 — 1 8 0 7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To:DRAYER PHYSICAL THERAPY INSTITUTE MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: TELEAMolnut Screet, Ste. 601 suPRPtacetlftT 14= • A-1TORNEY Dat Seal of the Coutt BY THE COU Pro hoar —r'="".'•ivil Divisi Deputy CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: DRAYER PHYSICAL THERAPY INSTITUTE - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff VS. MINNIE E. ROWE AND COUNTY OF CUMBERLAND Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:FAMILY EYE CARE PC CRAIG HENRY OD (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMELETICIA J.SANTIAGO, ESQUIRE ADDRESS: TELEPHONE: ,�,t �Q� S(i '(ii1E"' f6URT-ID # Tet ` ATTgRNEY FQ.RDENE liCit}+,jT 0.1.0 % .{i Date - Seal of the Cert Deputy CCLR• • moo— • Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: FAMILY EYE CARE, P.C. - CRAIG HENRY, O.D. Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff.. : File No.1 3 —1807 MINNIE E. AWE AND COUNTY • OF CUMBERLAND TO: Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 FIRST CHOICE REHABILITATION SEPCIALIST MEDICAL RECORDS DEPT. (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:LETICIA J. SANTIAGO, ESQUIRE ADDRES -.. 71, inc. 5 Walnut Street, to 601 LEPHO Eg t S +`�, D rk J ATTORN7V NORi:DE EJ ANP Date: 1• Seal of the Ccpr y BY THE COURT: ice► I Protho 'vision Deputy CLLR•••• Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: FIRST CHOICE REHABILITATION SPECIALISTS - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff : File No. MINNIE R. RO AND COUNTY OF CUMBERLAND Defendant 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:FOOS OBGYN PC MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAmE, LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CC Inc. 4 , TELE14010 101 SUPRfclifireWRI•! , ATTORNEY Wit: EN1j4k1T Date: Seai of the Cour BY THE COU Proth ivisio Deputy CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: FOOS OBGYN, PC - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED'*" (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff . MINNIE E. RUE AND COUNTY OF CUMBERLAND Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLCOMB CHIROPRACTIC CENTER (HCC OF CARLISLE PC) SHANNON HOLCOMB D.( (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ***SEE ATTACHED ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CL.e.., °1t S re TELEtPHONE: SUPREME COURT IDS ATTORNEY FOR: LA EN Date: Seal of the. Court Deputy Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: HOLCOMB CHIROPRACTIC CENTER (HCC OF CARLISLE PC) - SHANON HOLCOMB, D.C. Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff VS.' • MINNIE E. ROWE AND COUNTY OF CUMBERLAND Defendant File No. 1 3 -1 8 0 7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To:HOLY SPIRIT HOSPITAL MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** CENTER CITY LEGAL REPRODUCTIONS, INC. at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to thc 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: LETICIA J. SANTIAGO, ESQUIRE NAME: ADDRESS: TC -t --11—,.;=A.. IICG 01 TELEPHONE: le2T6':A .91O1 SUPREME, COURTI. 4_11 s: ATTORNEY FOR: MDAlt+ Date1/4.1 Scai °Tette ourt BY THE COURT. Prot shil aregor',Inviinivis n Deputy Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite.601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: HOLY SPIRIT HOSPITAL - MEDICAL RECORDS DEPT. Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff . : File No. VS. OIIFNCUEE MBEoI�LANDE AND COUNTY Defendant 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:HOLY SPIRIT HOSPITAL RADIOLOGY FILE ROOM (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things subpoena, together with the certificate of compliance, to the party making this request at above. You have the right to seek in advance the reasonable cost of preparing the copies things sought. If you fail to produce the documents or things required by this subpoena within after its service, the party serving this subpoena may seek a court order compelling you to requested by this the address listed or producing the twenty (20) days comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TO TIA SANTIAGO, ESQUIRE ininninWt. Street, Ste=. 601 1 hila k p _' p4 19107 TELEPHOIVNIE. SUPREM.Elear1R4` if) ATTORNEY FOR: DEFENDANT Date:,�� ,i_y_21 Sea! ofth!Court Deputy CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: HOLY SPIRIT HOSPITAL - RADIOLOGY FILE ROOM Re: KRISTA GROSS ANY AND ALL FILMS, MRI'S, CAT SCANS, X-RAYS, INCLUDING RADIOLOGY REPORTS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED " (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff . . File No. MINNIE E. ROWE.AND COUNTY OF CUMBERLAND Defendant 1 3-1 807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ORTHOPAEDIC & SPINE SPECIALISTS CHAD M. RUTTER, D.O. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ***SEE ATTACHED ADDENDUM*** CENTER CITY LEGAL REPRODUCTIONS, INC. at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMELETUC 1 MeTIAGO, ESQUIRE 13P EW Philadelphia, PA, 19107 TELEPHONV1 1 1 1 SUPREME MATT' rfrfr ATTORNEY FOR: DEFENDANT Seal of the BY THE COC Prot onota'ry; Civil Division Deputy _mak. Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: ORTHOPAEDIC & SPINE SPECIALISTS - CHAD M. RUTTER, D.O. Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS, ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff .: File No. 1 3 —1 8 07 MINNIE E. ROWESANDCOUNTY OF CUMBERLAND TO: Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 ORTHOPEDIC INSTITUTE OF PENNSYLVANIA RECORDS DEPARTMENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered b the court to produce the following documents or things: ***SEE ATTACHED ADDENDUM*** CENTER CITY LEGAL REPRODUCTIONS, INC. at (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FqJ Q.W.ING,PERSON: LETICIA J. SANTIAGO, ESQUIRE-�°-� .SDs;. ADME: ..._,1 15 `v mill. ut>;,"eei„ `�., 601 ADDRESS: ., i s a P hiih elpiuLnns PA ; ]07 6 1 S U) O JRT Jpt ATTORNEY FOR:Dr%t QQANT tT TJ • Dater•� 2 i Seal e'f the C ur, BY T 215-732-1177 i.T 11 l Iummawte._ maw - r thonotary, Civil Divisi in Deputy CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: ORTHOPEDIC INSTITUTE OF PENNSYLVANIA - RECORD DEPARTMENT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. *` CERTIFICATION PAGE MUST BE SIGNED AND DATED''" (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff . : File No. MINNIE E. ROWSAND COUNTY OF CUMBERLAND Defendant 1 3-1 807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER PERSONNEL DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: C.CLR inc. TA4440 winu SUPR > 4 tVI,bh#?.. A. 19107 ATTORNEY Date:, ' � Seal of ofthe€ourt Deputy „gab, CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: PENN STATE MILTON S. HERSHEY MEDICAL CTR. - PERSONNEL DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ”" CERTIFICATION PAGE MUST BE SIGNED AND DATED "" (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff .: File No. 13-1807 VS. MINNIE E. ROWE AND COUNTY OF CUMBERLAND Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: UROLOGY OF CENTRAL PA INC MEDICAL RECORDS DEPARTMENT (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:LETICIA J. SANTIAGO, ESQUIRE ADDRESS: _ sco 601 SUPT r ; l ppu `�. 1 •. F DANT • ATTORNEY.F.OR: Y �y Date:lit..1p2J / Seal cfthe Curt / BY THE C Pro"'"'otary, Civil Iivisio Deputy CCLR . • . Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: UROLOGY OF CENTRAL PA, INC. - MEDICAL RECORDS DEPT Re: KRISTA GROSS ANY AND ALL MEDICAL RECORDS, INCLUDING FILMS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** (DOB: 11/20/1984) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KRISTA NICHOLE GROSS Plaintiff VS. MINNIE E. ROWE AND COUNTY OF CUMBERLAND Defendant File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:WALNUT BOTTOM RADIOLOGY—RADIOLOGY FILE ROOM (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 ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS, INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMELETICIA J. SANTIAGO, ESQUIRE ADDRESS: CCLR. Inc. -1311.616mst it < , r , , ¢ ., ,. , 01 SUP ���,,,# UjtT ID #, • • , ATT r R ' DEPENDAI(T BY THE COURT. AO_ ff4 Prot .r?ary, Civil Division Date: • J rt Seal of the C6u Deputy Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-03053LG ************************** ADDENDUM TO SUBPOENA ************************** To: WALNUT BOTTOM RADIOLOGY - RADIOLOGY FILE ROOM Re: KRISTA GROSS ANY AND ALL FILMS, MRI'S, CAT SCANS, X-RAYS, INCLUDING RADIOLOGY REPORTS, ETC., PERTAINING TO KRISTA GROSS.** CERTIFICATION PAGE MUST BE SIGNED AND DATED " (DOB: 11/20/1984) 14-07589LG CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 In the Matter of: Court of Common Pleas KRISTA NICHOLE GROSS Cumberland County -VS- MINNIE E. ROWE AND COUNTY OF No. 13-1807 CUMBERLAND As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of LETICIA J. SANTIAGO, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s) with a copy of the subpoena(s) attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s) which will be served is/are identical to the subpoena(s) which is/are.:. attached to the notice of intent to serve the subpoena(s). �~ DATE: 10/14/2014 CD LETICIA J. SANTIAGO, ESQUIRE Counsel for Defendant CD -11 CCLR IN Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com KRISTA NICHOLE GROSS VS. MINNIE E. ROWE AND COUNTY OF No. 13-1807 CUMBERLAND IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS REGINA MCILVAINE, ESQUIRE LOWENTHAL & ABRAMS, P.C. 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 Please take notice there has been a request by LETICIA J. SANTIAGO, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to KRISTA GROSS. Enclosed is(are) a copy (copies) of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: September 22, 2014 Enclosures : Copy (copies) of Subpoena(s) Counsel Return Page Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com KRISTA NICHOLE GROSS vs. MINNIE E. ROWE AND COUNTY OF CUMBERLAND CCLR File NO. 14-07589LG COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 9/22/2014 regarding records in the custody of (see attached subpoena(s)) and respond as follow: (Ordering records through CCLR is more cost effective than getting them from a provider or another service carrier - see rates below) (1) COPIES I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) (3) I would like copies of X -Rays on CD sent to me. OBJECTION In accordance to rules governing civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions prior to 10/14/2014. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) I would like to look at the records at a Center City location before deciding whether to order a copy. 2014 Copy Fees/Per Location Administrative Fee Pages 1-20 Pages 21-60 Pages 61 & Above X -Rays on CD $18.00 $1.00 $.70 $.25 $25.00/CD If Billing is NOT to Firm Bill -to Company: Adjuster Name: Claim Number:: Address: Attorney for plaintiff(s) / defendant(s) REGINA MCILVAINE, ESQUIRE LOWENTHAL & ABRAMS, P.C. 555 CITY LINE AVENUE SUITE 500 BALA CYNWYD, PA 19004 (but to an insurance company, etc.), enter the bill -to information below: yes / no yes / no yes / no Date KRISTA NICHOLE GROSS VS MINNIE E. ROWE AND COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: MICHAELS® ART SUPPLIES PERSONNEL DEPT (Name of Person or Entity) AT: Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things **SEE ATTACHED ADDENDUM** CENTER CITY LEGAL REPRODUCTIONS, INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET, SUITE 601 PHILADELPHIA. PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: BY THE COURT: Seal of the Court Prothonotary /Clerk, Civil Disposition Deputy (Eff.7/97) CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-07589LG ************************** ADDENDUM TO SUBPOENA ************************** To: MICHAELS® ART SUPPLIES - PERSONNEL DEPT Re: KRISTA GROSS ANY AND ALL EMPLOYMENT/PERSONNEL RECORDS, WORKERS' COMP CLAIMS, DATES OF ATTENDANCE, APPLICATIONS, PERFORMANCE RECORDS, DISCIPLINARY RECORDS, REVIEWS, EVALUATIONS, EARNINGS, MEDICAL REPORTS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** KRISTA NICHOLE GROSS vs MINNIE E. ROWE AND COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PA HIGHER EDUCATION ASSISTANCE AGENCY (PHEAA) PERSONNEL DEPT (Name of Person or En(ity) AT: Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things **SEE ATTACHED ADDENDUM** CENTER CITY LEGAL REPRODUCTIONS, INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET, SUITE 601 PHILADELPHIA, PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: BY THE COURT: Seal of the Court Prothonotary /Clerk, Civil Disposition Deputy (Eff.7/97) CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-07589LG ************************** ADDENDUM TO SUBPOENA ************************** To: PA HIGHER EDUCATION ASSISTANCE AGENCY (PHEAA) - PERSONNEL DEPT Re: KRISTA GROSS ANY AND ALL EMPLOYMENT/PERSONNEL RECORDS, WORKERS' COMP CLAIMS, DATES OF ATTENDANCE, APPLICATIONS, PERFORMANCE RECORDS, DISCIPLINARY RECORDS, REVIEWS, EVALUATIONS, EARNINGS, MEDICAL REPORTS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** KRISTA NICHOLE GROSS vs MINNIE E, ROWE AND COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: RAY'S FAMILY RESTAURANT PERSONNEL DEPT (Name of Person or Entity) AT: Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things **SEE ATTACHED ADDENDUM** CENTER CITY LEGAL REPRODUCTIONS, INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET, SUITE 601 PHILADELPHIA, PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: BY THE COURT: Seal of the Court Prothonotary /Clerk, Civil Disposition Deputy (Eff.7/97) CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-07589LG ************************** ADDENDUM TO SUBPOENA ************************** To: RAY'S FAMILY RESTAURANT - PERSONNEL DEPT Re: KRISTA GROSS ANY AND ALL EMPLOYMENT/PERSONNEL RECORDS, WORKERS' COMP CLAIMS, DATES OF ATTENDANCE, APPLICATIONS, PERFORMANCE RECORDS, DISCIPLINARY RECORDS, REVIEWS, EVALUATIONS, EARNINGS, MEDICAL REPORTS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** KRISTA NICHOLE GROSS VS MINNIE E. ROWE AND COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: RITE AID CORPORATION LEGAL DEPT. (Name of Person or Entity) AT: Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things **SEE ATTACHED ADDENDUM** CENTER CITY LEGAL REPRODUCTIONS, INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET, SUITE 601 PHILADELPHIA, PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: BY THE COURT: Seal of the Court Prothonotary /Clerk, Civil Disposition Deputy (Eff.7/97) „gat,. CCLR Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-07589LG ************************** ADDENDUM TO SUBPOENA ************************** To: RITE AID CORPORATION - LEGAL DEPT. Re: KRISTA GROSS ANY AND ALL EMPLOYMENT/PERSONNEL RECORDS, WORKERS' COMP CLAIMS, DATES OF ATTENDANCE, APPLICATIONS, PERFORMANCE RECORDS, DISCIPLINARY RECORDS, REVIEWS, EVALUATIONS, EARNINGS, MEDICAL REPORTS, ETC., PERTAINING TO KRISTA GROSS. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED ** KRISTA NICHOLE GROSS VS MINNIE E. ROWE AND COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: TORRES CREDIT SERVICE PERSONNEL DEPT (Name of Person or Entity) AT: Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things **SEE ATTACHED ADDENDUM** CENTER CITY LEGAL REPRODUCTIONS, INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET, SUITE 601 PHILADELPHIA, PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: BY THE COURT: Seal of the Court Prothonotary /Clerk, Civil Disposition Deputy (Eff.7/97) Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-07589LG ************************** ADDENDUM TO SUBPOENA ************************** To: TORRES CREDIT SERVICE - PERSONNEL DEPT Re: KRISTA GROSS ANY AND ALL EMPLOYMENT/PERSONNEL RECORDS, WORKERSCOMP CLAIMS, DATES OF ATTENDANCE, APPLICATIONS, PERFORMANCE RECORDS, DISCIPLINARY RECORDS, REVIEWS, EVALUATIONS, EARNINGS, MEDICAL REPORTS, ETC., PERTAINING TO KRISTA GROSS. CERTIFICATION PAGE MUST BE SIGNED AND DATED KRISTA NICHOLE GROSS VS MINNIE E. ROWE AND COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 13-1807 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: TYPICAL LIFE CORPORATION SOCIAL SERVICES ORGANIZATION (Name of Person or Entity) AT: Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things **SEE ATTACHED ADDENDUM** CENTER CITY LEGAL REPRODUCTIONS, INC (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate 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 is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: LETICIA J. SANTIAGO, ESQUIRE ADDRESS: CENTER CITY LEGAL REPRODUCTIONS, INC. 1315 WALNUT STREET, SUITE 601 PHILADELPHIA, PA 19107 TELEPHONE: 215-732-1177 SUPREME COURT ID# ATTORNEY FOR: DEFENDANT DATE: BY THE COURT: Seal of the Court Prothonotary /Clerk, Civil Disposition Deputy (Eff7/97) Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-07589LG ************************** ADDENDUM TO SUBPOENA ************************** To: TYPICAL LIFE CORPORATION - SOCIAL SERVICES ORGANIZATION Re: KRISTA GROSS ANY AND ALL EMPLOYMENT/PERSONNEL RECORDS, WORKERS' COMP CLAIMS, DATES OF ATTENDANCE, APPLICATIONS, PERFORMANCE RECORDS, DISCIPLINARY RECORDS, REVIEWS, EVALUATIONS, EARNINGS, MEDICAL REPORTS, ETC., PERTAINING TO KRISTA GROSS. "" CERTIFICATION PAGE MUST BE SIGNED AND DATED **