Loading...
HomeMy WebLinkAbout13-4018 Supreme Co o P �nnsylvania Con' o &Commo leas For Prothonotary Use Only: Cl! iI r , Yver'Sh. t �e � Docket No: Cu ,8 .BLAND r 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 ofpleadings or other papers as required by law or rules ofcourt. Commencement of Action: S n Complaint [9 Writ of Summons ® Petition 0 Transfer from Another Jurisdiction ® Declaration of Taking .E C Lead Plaintiff's Name: Lead Defendant's Name: Raina M. Miller Ralph Clay iT Dollar Amount Requested: ®within arbitration limits I Are money damages requested? Yes No O (check one) ®x outside arbitration limits � N Is this a Class Action Suit? ® Yes No Is this an MDJAppeal? ® Yes El No A Name of Plaintiff /Appellant's Attorney: Dennis J. Shatto ® Check here if you have no attorney (are a Self- Represented (Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your E PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. 4 TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution D Debt Collection: Credit Card ® Board of Assessment lR Motor Vehicle ® Debt Collection: Other ® Board of Elections Nuisance Dept. of Transportation ® Premises Liability H Statutory Appeal: Other S ® Product Liability (does not include E mass tort) Employment Dispute: 13 Slander/Libel/ Defamation Discrimination C ® Other: ® Employment Dispute: Other ® Zoning Board h T Other: I ® Other: O MASS TORT I ® Asbestos N ® Tobacco ® Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ' ®Ejectment E3 Common Law /Statutory Arbitration [3 Other: A ® Eminent Domain /Condemnation ® Declaratory Judgment 13 Ground Rent ® Mandamus ® Landlord/Tenant Dispute ® Non - Domestic Relations U Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY E3 Mortgage Foreclosure: Commercial ® Quo Warranto r3 Dental ® Partition ® Replevin 1 ® Legal ® Quiet Title ® Other: l3 Medical ® Other: ® Other Professional: I Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff(s).& Address(es) RAINA M. MILLER 1000 N. U.S. Route 15 Diilsburg, PA 17019 Case No. Civil Term VS. Civil Action - L Defendant(s) & Address(es) _ RALPH CLAY w —c 301 W. Elmwood Ave MCD Mechanicsburg, PA 17055. `+ c" N -4.M PRAECIPE FOR WRIT OF SUMMONS''. TO THE PROTHONOTARY /CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwarded to Attor e S eriff lease Circle choice Date : Z 2 013 Signature of Attorney Print Name: Dennis J. Shatto Address: 119 Locust St Harrisburg, PA 17901 Telephone #: 717-238 -1731 Supreme Court ID Number: 25675 WRIT OF SUMMONS TO: RALPH CLAY YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFFS) H VE COMMENCED AN ACTJON AGAINST YOU. , - - Prothonotary/Clerk, Civil Division Date: Deputy 0 Ix 1 .s Ac� CKW i3 Wv SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FL.EU-t : Jody S Smith 4�� �� OF TU4E PRO #HONO l�It'�,Y Chief Deputy . f,,a& 2013 JUL 18 AM 10= GC Richard W Stewart Solicitor M I rOF7�riS,� RIPF CUMBERLAND COUNTY PENNSYLVANIA Raina M. Miller VS. Case Number Ralph Clay 2013-4018 SHERIFF'S RETURN OF SERVICE 07/15/2013 02:59 PM-Deputy Jamie DiMartle, being duly sworn according to law, served the requested Writ of Summons by"personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Ralph Clay at 301 W. Elmwood Avenue, Mechanicsburg Borough, Mechanicsburg, PA 17055. (j),MI DI R DEPUTY SHERIFF COST: $39.76 SO ANSWERS, July 16,2013 RONNY R ANDERSON, SHERIFF I (c)County$uite Sheriff,Teieosoft,Inc. r.0 3 DEC 19 H C,UMBE.RLAN0 BO'j'1 T PENNSYLVANIA ANIA Johnson, Duffie, Stewart & Weidner By: John A. Lucy, Esquire I.D. No. 203948 Attorneys for Defendant, 301 Market Street Ralph Clay P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal @jdsw.com RAINA M. MILLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-4018 RALPH CLAY, Defendants CIVIL ACTION — LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as counsel for Defendant, alph Clay, in the above- captioned matter. JOHNSON, D- E, STEWART & WEIDNER B Jo . Lucy, Esquire or ey I.D. No. 203948 0 Market Street, P.O. Box 109 moyne, PA 17043-0109 (717) 761-4540 jal @jdsw.com Date: December 18, 2013 Counsel for Defendant, Ralph Clay 597359 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe for Entry of Appearance has been duly served upon all counsel of record by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on December 18, 2013, as follows: Dennis J. Shatto, Esquire Cleckner & Fearen 119 Locust Street Harrisburg, PA 17101 Counsel for Plaintiff JOHNSON, DUPFIE, STEWART & WEIDNER BY: -°6Fnr Lucy r 597359 .it C1, raTri, t p i t Gik 1 i` b �\� trt DC 19 2 CUMBERLAND COUH l " PENNSYLVANIA Johnson, Duffie, Stewart & Weidner By: John A. Lucy, Esquire I.D. No. 203948 Attorneys for Defendant, 301 Market Street Ralph Clay P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal @jdsw.com RAINA M. MILLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-4018 RALPH CLAY, Defendants CIVIL ACTION — LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule on the Plaintiff to file a Camp int within twenty (20) days of the date of service thereof, or suffer judgment of non pros JO,' NSON, D FIE, STEWART & WEIDNER B ` ��--Je .Lucy, Esquire Attorn y I.D. No. 203948 : 301 M rket Street, P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jal @jdsw.com Date: December 18, 2013 Counsel for Defendant, Ralph Clay 597361 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe for Rule to File Complaint has been duly served upon all counsel of record by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on December 11, 2013, as follows: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 Counsel for Plaintiff JOHNSON, D FIE, ST WART &WEIDNER BY: i ohn A. Lea #596331 Johnson, Duffie, Stewart & Weidner By: John A. Lucy, Esquire I.D. No. 203948 Attorneys for Defendant, 301 Market Street Ralph Clay P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal @jdsw.com RAINA M. MILLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-4018 RALPH CLAY, Defendants CIVIL ACTION — LAW JURY TRIAL DEMANDED RULE TO FILE COMPLAINT TO THE PLAINTIFF: You are hereby directed to file a Complaint in the above-captioned matter within 20 days or judgment non pros will be entered against you. DATE: P O H0N0TARY 597361 d rH PROTHONQT.A `t. 2013 DEC 26 PH 3 10 CUMBERLAND COUNTY PENNSYLVANIA Johnson, Duffie, Stewart & Weidner By: John A. Lucy, Esquire I.D. No. 203948 Attorneys for Defendant, 301 Market Street Ralph Clay P. O. Box 109 Lemoyne., Pennsylvania 17043-0109 (717) 761-4540 jaI @jdsw.com RAINA M. MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 13-4018 RALPH CLAY, Defendants : CIVIL ACTION — LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Rule to File Complaint issued by the Court on December 19, 2013, has been duly served upon all counsel of record by depositing de ositin the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on December 23, 2013, as follows: Dennis J. Shatto, Esquire Cleckner and Fearen 119 Locust Street P.O. Box 11847 Harrisburg, PA 17108-1847 Counsel for Plaintiff 598063 Respectfully sub••• ed, JOHN a N, DUFFIE, ST- ART &WEIDNER Y: /! • n A. u► , squire Attor -y .D. No. 203948 304i) -rket Street P •. Box 109 emoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant, Ralph Clay 598063 Dennis J. Shatto, Esquire y+� � � Pa. Attorney ID 25675 14 P11 0 Cleckner and Fearen 119 Locust Street t1P°IBERLANo COUNTY P. 0. Box 11847 PENNS YLVA ' Harrisburg, PA 17108-1847 NIA Tele: (717) 238-1731 Fax: (717) 238-8481 E-mail: derir isshattOCf,.ot:na 1 .com Attorneys for Plaintiff RAINA M. MILLER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs . CIVIL ACTION - LAW RALPH CLAY, NO. 2013-CV-4018 Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 A V I S 0 USTED HA SIDO DEMANDADO/A EN COURTS. Si usted desea defenderse de las demandas que se presentan m6s adelante en las siguientes pAginas, debe tomar acci6n dentro de los proximos veinte (20) dias despu6s de la notificaci6 de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualguier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mAs aviso adicional . Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABODAGO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 Dennis J. Shatto, Esquire Pa. Attorney ID 25675 Cleckner and Fearen 119 Locust Street P. 0. Box 11847 Harrisburg, PA 17108-1847 Tele: (717) 238-1731 Fax: (717) 238-8481 dennisshatto @hotmail . com Attorneys for Plaintiff RAINA M. MILLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS . NO. 2013-4018-CV RALPH CLAY, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1 . Plaintiff is Raina M. Miller, an unmarried adult individual who resides at 4822 East Trindle Road, Mechanicsburg, Pennsylvania, 17050 . 2 . Defendant is Ralph Clay, an adult individual who resides at 301 W. Elmwood Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17055 . 3 . On July 15, 2011, Plaintiff and Defendant were involved in an automobile collision which occurred ay the intersection of Market and Main Streets in the Borough of Mechanicsburg, Cumberland County, Pennsylvania. 4 . At the time and place aforesaid, Plaintiff was operating a 2001 Mercury Cougar, bearing license plate number HKG-7458 in a southerly direction on North Market Street, intending to proceed straight at the intersection with Main Street . 5 . Defendant was operating a 2001 Chevrolet Venture bearing license plate number DYV-3605, in a northerly direction on south Market Street, intending to turn left onto West Main Street . 6. As the Plaintiff entered the intersection, Defendant turned left, directly into Plaintiff' s path of travel, and the vehicles collided. 7 . The collision of the vehicles was caused by the negligence of Defendant, as follows : a. Making a left turn directly into the path of Plaintiff' s vehicle, when it was unsafe to do so; b. Failing to yield the right-of-way to Plainfiff; C. Failing to wait until Plaintiff cleared the intersection before attempting to make his left turn. 8 . As a direct result of the Defendant' s negligence as aforesaid, Plaintiff suffered the following injuries and conditions, all of which are permanent : a. Post-concussional syndrome, cervicicalgia and dizziness; b. Daily headaches; C. Fatigue; d. Impaired vision e . Pain and suffering - 2 - 9 . Plaintiff' s headaches are so severe that she sometimes is completely incapacitated and must lie down, has missed work and has had to reduce her hours of work. 10 . As a direct result of Defendant' s negligence, Plaintiff has suffered, and will continue in the future to suffer, from pain, mental anguish, inconvenience and impairment of activity and enjoyment of life . 11 . As a direct result of Defendant' s negligence, Plaintiff has suffered a loss of earnings and a loss of earning capacity, which may be permanent . 12 . As a direct result of Defendant' s negligence, Plaintiff has incurred hospital and medical expenses for the treatment of his injuries, and may continue to incur such expenses in the future. WHEREFORE, Plaintiff demands judgment against Defendant in an amount which exceeds the limit for mandatory arbitration. CLECKNER AND EAREN Dated: By Dennis J - atto Esquire Pa. Attorney ID #25675 119 Locust Street P. 0. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 Attorneys for Plaintiff, Samuel M. Hester - 3 - VERIFICATION I, RAINA M. MILLER, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C. S .A. §4904 relating to unsworn falsification to authorities . Date. D�/ � 4i'�. RAINA M. MILLER CERTIFICATE OF SERVICE I, DENNIS J. SHATTO, hereby certify that on this day, I served a true and correct copy of the foregoing Complaint upon the person indicated below, by depositing same in the United States mail, first class postage prepaid, addressed as follows : John A. Lucy, Esquire Johnson Duffie P.O. Box 109 Lemoyne, PA 17043-0109 CLECKNER AND FEAREN Dennis J. Shatto, Esquire PA Attorney ID 25675 119 Locust Street Date: �3� 2�ly P. 0. Box 11847 Harrisburg, PA 17108-1847 (717) 238-1731 "�tt jilt, 29 /; c Y�AVI ENNS A UNTY �A Johnson, Duffie, Stewart &Weidner By: John A. Lucy, Esquire I.D. No. 203948 Attorneys for Defendant, 301 Market Street Ralph Clay P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal @jdsw.com RAINA M. MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 2013-CV-4018 RALPH CLAY, : CIVIL ACTION — LAW Defendant : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiff do Dennis J. Shatto, Esquire Cleckner & Fearen 119 Locust Street P.O. Box 11847 Harrisburg, PA 17108-1847 AND NOW, this 28th day of January, 2014, you are hereby notified to plead responsively within twenty (20) days of the date of servi - e =of, or judgment may be entered against you. JOHNSrN, DUFFIE, :TE MART & WEIDNER BY J.- A. ucy, Esquire (I.D. No. 203948) 301 :rket Street, P.O. Box 109 Le , yne, PA 17043-0109 (7//) 761-4540 %I @jdsw.com Counsel for Defendant, Ralph Clay Johnson, Duffie, Stewart & Weidner By: John A. Lucy, Esquire I.D. No. 203948 Attorneys for Defendant, 301 Market Street Ralph Clay P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jal @jdsw.com RAINA M. MILLER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA v. : NO. 2013-CV-4018 RALPH CLAY, : CIVIL ACTION — LAW Defendant : JURY TRIAL DEMANDED ANSWER OF DEFENDANT, RALPH CLAY, TO PLAINTIFF'S COMPLAINT WITH NEW MATTER AND NOW, comes Defendant, Ralph Clay, by and through his counsel, John A. Lucy, Esquire and Johnson, Duffie, Stewart & Weidner, P.C., and files his Answer to Plaintiff's Complaint with New Matter as follows: 1. Admitted. 2. Admitted. 3. Admitted. • 4. Admitted upon information and belief. 5. Admitted. 6. Admitted in part; denied in part. It is admitted only that there was a collision between the Plaintiff's vehicle and the Defendant's vehicle which occurred on the date, time, and place averred. As to the remainder of the allegations, they are hereby denied generally pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is demanded at the time of trial. 7. (a) — (c). Paragraph 7 and all of its subparts set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 8. (a) — (e). Paragraph 8 and all of its subparts set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 9. After reasonable investigation, Answering Defendant is without knowledge or information to form a belief as to the truth or falsity of the averments contained in Paragraph 9 and the same is therefore denied and strict proof is demanded at the time of trial. 10. Paragraph 10 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 11. Paragraph 11 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 601334 2 12. Paragraph 12 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. NEW MATTER 13. That Plaintiff's alleged cause of action may be barred by the applicable statute of limitations. 14. That Plaintiff's alleged cause of action may be barred by the Pennsylvania Motor Vehicle Financial Responsibility Law and the limited tort option. 15. That Plaintiff did not sustain a significant impairment of bodily function. 16. That if it should be found that there is any negligence on the part of Defendant, Ralph Clay, which is denied, then in that event any such negligence was not a factual cause of the Plaintiff's harm. 17. That Plaintiffs alleged harm may have been pre-existing. 18. That the Plaintiff's alleged cause of action may have been caused by third parties or entities not presently involved in this action. 19. That the Plaintiff may have failed to mitigate her alleged damages. 20. That the Plaintiff's alleged cause of action may be barred in whole or in part by the Pennsylvania Comparative Negligence Act. 21. That the Plaintiff's alleged caused of action may be barred in whole or in part by Plaintiff's own comparative negligence. 601334 3 WHEREFORE, Defendant, Ralph Clay, hereby respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. Respectfully sub • JOHNSON •UFFIE, ST' WART & WEIDNER BY: d . Jo • • . Lucjquire Attorney I.). o. 203948 301 Mar. -t Street P.O. : 109 Lem.one, PA 17043-0109 (71 ) 761-4540 jal @jdsw.com Counsel for Defendant, Ralph Clay Date: January 28, 2014 601334 4 VERIFICATION I, Ralph Clay, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing Answer to Plaintiff's Complaint with New Matter; and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. 10_40-04 '' _// Dated: 170-0/ , 2014 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Answer of Defendant, Ralph Clay, to Plaintiff's Complaint with New Matter has been duly served upon all counsel of record by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on January 28, 2014, as follows: Dennis J. Shatto, Esquire Cleckner & Fearen 119 Locust Street P.O. Box 11847 Harrisburg, PA 17108-1847 Counsel for Plaintiff n A. fcy • 0!TICE -2014'Eli,.; �� ��, r�U3`'U TAF ,. CERTIFICATE ` r CUHBERL A ND COUNT PREREQUISITE TO SERVICE OF A SUBP,CLI+M Y� �P IA PURSUANT TO RULE 4009.22 IN THE MALI ER OF: Court of Common Pleas-Cumberland County,PA RAINA M.MILLER vs. TERM: RALPH CLAY CASE No: 13-4018 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 02/20/2014 RecordTrak on behalf of /S/JOHN LUCY Attorney for Defendant f RT#: 262155 RECORDS PERTAIN TO: RAINA MILLER RAINA M. MILLER • COURT: Court Of Common Pleas-Cumberland County,Pa vs. : TERM: RALPH CLAY : DOCKET: 13-4018 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS TO: DENNIS J. SHATTO CLECKNER&FEAREN 119 LOCUST STREET P.O.BOX 11847 HARRISBURG,PA 17101 (717)238-8481 January 30, 2014 Please take notice that on behalf of JOHN LUCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s)attached to this notice. You have until February 19, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made,the subpoena(s)will be served. IF PLAINTIFF'S COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD,PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS,PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY February 19,2014 TO(610)992-1405. All records will be provided(including no record statements)as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia,PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN I TERIALS BEING OBTAINED 1 PMA INSURANCE 1 .COPIES OF ENTIRE WORKERS'COMPENSATION CLAIM FILE NO.0000W09870, COMPANIES(CL#0000W09870) I'OLICY NO.2009007642788,TO INCLUDE,BUT NOT LIMITED TO ORRESPONDENCE,CLAIMS NOTES,FORMS,MEDICAL RECORDS, II VESTIGATIONS,STATEMENTS,AND A SUMMARY OF PAYMENTS MADE TO I• • I A M.MILLER,DOB:4/12/1991,SS#XXX-XX-9080,FROM 06/25/10 TO THE PRESENT. 2 PMA INSURANCE 1 .COPIES OF ENTIRE WORKERS'COMPENSATION CLAIM FILE NO.0002W20397, COMPANIES(CL#0002W20397) POLICY NO.2010007642788,TO INCLUDE,BUT NOT LIMITED TO ORRESPONDENCE,CLAIMS NOTES,FORMS,MEDICAL RECORDS, II VESTIGATIONS,STATEMENTS,AND A SUMMARY OF PAYMENTS MADE TO I• • I A M.MILLER,DOB:4/12/1991,SS#XXX-XX-9080,FROM 04/15/2011 TO THE I'RESENT. 3 FAMILY PRACTICE CENTER 1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 12/05/04 TO THE OF LOYSVILLE I'RESENT. INCLUDING,BUT NOT LIMITED TO OFFICE AND HAND WRITTEN I OTES,TEST RESULTS,CORRESPONDENCE,QUESTIONNAIRES/HISTORY& I' CORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE I'AIIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL • •CHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CER I I'ICATION AND RETURN THE RECORDS.************** RAINA M.MILLER COURT: Court Of Common Pleas- Cumberland County,Pa vs. TERM: RALPH CLAY : DOCKET: 13-4018 4 ERIE INSURANCE 1 .COPIES OF ALL DOCUMENTS INCLUDING ENTIRE FIRST-PARTY BENEFITS EXCHANGE(CL#010171174769002) I ILE,APPLICATION FOR BENEFITS,PIP PAYOUT SUMMARY,ALL I I MORANDA,REPORTS,STATEMENTS,MEDICAL RECORDS,PHONE I I SSAGES,ADJUSTER NOTES,EXPERT REPORTS,TORT ELECTION FORM, POLICY INFORMATION AND ANY OTHER DOCUMENTATION PERTAINING TO I' I A M.MILLER,DOB:4/12/1991;SS#XXX-XX-9080; CLAIM NO: 110171174769002 5 ERIE INSURANCE 1 .COPIES OF ALL DOCUMENTS INCLUDING ENTIRE FIRST-PARTY BENEFITS EXCHANGE I ILE,APPLICATION FOR BENEFITS,PIP PAYOUT SUMMARY,ALL (CL#01017106705995110538) I I MORANDA,REPORTS,STATEMENTS,MEDICAL RECORDS,PHONE I I SSAGES,ADJUSTER NOTES,EXPERT REPORTS,TORT ELECTION FORM, I'OLICY INFORMATION AND ANY OTHER DOCUMENTATION PERTAINING TO I' I A M.MILLER,DOB:4/12/1991;SS#XXX-XX-9080;CLAIM NO.: 11017106705995110538 Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: Date: FIRM: YES,I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: • • Page 2 RT: 262155.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M.MILLER V. RALPH CLAY File No:13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:PMA INSURANCE COMPANIES (Name of Person or Entity) Within twenty (20)days after service of this subpoena,you are ordered by the Court to produce the following documents or things: See attached rider. • at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing 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:RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800)220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant Prothonotary DATE: I f Y . • • • Seal of the Court • RE: RAINA M.MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE#: 262155; TAG 1 LOCATION:PMA INSURANCE COMPANIES(CL#0000W09870) RECORDS PERTAIN TO:RAINA MILLER SS#: ,DOB: 1 .COPIES OF ENTIRE WORKERS'COMPENSATION CLAIM FILE NO. 0000W09870,POLICY NO.2009007642788,TO INCLUDE,BUT NOT LIMITED TO CORRESPONDENCE,CLAIMS NOTES,FORMS,MEDICAL RECORDS, INVESTIGATIONS,STATEMENTS,AND A SUMMARY OF PAYMENTS MADE TO RAINA M.MILLER,DOB:4/12/1991,SS#XXX-XX-9080,FROM 06/25/10 TO THE PRESENT. RT: 262155.2 • COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M.MILLER V. RALPH CLAY File No:13-4018 • SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:PMA INSURANCE COMPANIES (Name of Person or Entity) Within twenty (20)days after service of this subpoena,you are ordered by the Court to produce the • following documents or things: See attached rider. • at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20)days afte: 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:RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant 1 Prothonotary DATE: !p JY• . Seal of the Court RE:RAINA M.MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE#: 262155; TAG 2 LOCATION: PMA INSURANCE COMPANIES(CL#0002W20397) RECORDS PERTAIN TO: RAINA MILLER SS#: ,DOB: 1 .COPIES OF ENTIRE WORKERS'COMPENSATION CLAIM FILE NO. 0002W20397,POLICY NO.2010007642788,TO INCLUDE,BUT NOT LIMITED TO CORRESPONDENCE,CLAIMS NOTES,FORMS,MEDICAL RECORDS, INVESTIGATIONS,STATEMENTS,AND A SUMMARY OF PAYMENTS MADE TO RAINA M.MILLER,DOB:4/12/1991,SS#XXX-XX-9080,FROM 04/15/2011 TO THE PRESENT. RT: 262155.3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M.MILLER V. RALPH CLAY Fite No:13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY, PURSUANT TO RULE 4009.22 TO:FAMILY PRACTICE CENTER OF LOYSVILLE (Name of Person or Entity) Within twenty (20)days after service of this subpoena,you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing 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:RecordTrak,JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800)220-1291 BY THE COURT.: Supreme Court ID# Attorney for:Defendant X� Prothonotary DATE: 0 �D 1 4 4, Seal of the Court RE:RAINA M.MILLER vs.RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE#: 262155; TAG 3 LOCATION:FAMILY PRACTICE CENTER OF LOYSVILLE RECORDS PERTAIN TO:RAINA MILLER SS#: ,DOB: 1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 12/05/04 TO THE PRESENT. INCLUDING,BUT NOT LIMITED TO OFFICE AND HAND WRITTEN NOTES,TEST RESULTS,CORRESPONDENCE,QUESTIONNAIRES/HISTORY& RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** RT: 262155.4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M.MILLER V. RALPH CLAY File No:13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:ERIE INSURANCE EXCHANGE (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: Sec attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty(20)days site 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:RecordTrak,JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (80Q)220-1291 BY THE COURT: Supreme Court ID# Attorney for:Defendant t IA-EL DATE: �D fV Prothonotary Seal of the Court RE:RAINA M.MILLER ER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE#: 262155; TAG 4 LOCATION: ERIE INSURANCE EXCHANGE(CL#010171174769002) RECORDS PERTAIN TO:RAINA MILLER SS#: ,DOB: 1 .COPIES OF ALL DOCUMENTS INCLUDING ENTIRE FIRST-PARTY BENEFITS FILE,APPLICATION FOR BENEFITS,PIP PAYOUT SUMMARY,ALL MEMORANDA, REPORTS,STATEMENTS,MEDICAL RECORDS,PHONE MESSAGES,ADJUSTER NOTES,EXPERT REPORTS,TORT ELECTION FORM,POLICY INFORMATION AND ANY OTHER DOCUMENTATION PERTAINING TO RAINA M.MILLER,DOB: 4/12/1991;SS#XXX-XX-9080; CLAIM NO:010171174769002 ImmimmimmmEim RT: 262155.5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M.MILLER V. RALPH CLAY File No:13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:ERIE INSURANCE EXCHANGE (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoew together with the certificate of compliance,to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty(20)days etc 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: RecordTrak,JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone:, (800)220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant • DATE: C294A Prothonotary Seal of the Court J r ^ K RE:RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE#: 262155; TAG 5 LOCATION:ERIE INSURANCE EXCHANGE(CL#01017106705995110538) RECORDS PERTAIN TO: RAINA MILLER SS#: ,DOB: 1 .COPIES OF ALL DOCUMENTS INCLUDING ENTIRE FIRST-PARTY BENEFITS FILE,APPLICATION FOR BENEFITS,PIP PAYOUT SUMMARY,ALL MEMORANDA, REPORTS,STATEMENTS,MEDICAL RECORDS,PHONE MESSAGES,ADJUSTER NOTES,EXPERT REPORTS,TORT ELECTION FORM,POLICY INFORMATION AND ANY OTHER DOCUMENTATION PERTAINING TO RAINA M.MILLER,DOB: 4/12/1991;SS#XXX-XX-9080;CLAIM NO.:01017106705995110538 CERTIFICATEfY CDr �'apy 1 l 2 PREREQUISITE TO SERVICE OF A SUBPOENA p� i'LS Y;1D cQu ti PURSUANT TO RULE 4009.22 ✓Q NIA r 1, /c,/‘, D IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA RAINA M. MILLER vs. TERM: RALPH CLAY CASE No: 13-4018 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 05/16/2014 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant RT#: 262155 RECORDS PERTAIN TO: RAINA MILLER RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: RALPH CLAY NOTICE TO: DENNIS J. SHATTO CLECKNER & FEAREN 119 LOCUST STREET P.O. BOX 11847 HARRISBURG, PA 17101 (717) 238-8481 April 25, 2014 : DOCKET: 13-4018 OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS Please take notice that on behalf of JOHN LUCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until May 15, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF PLAINTIFF'S COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY May 15, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN MATERIALS BEING OBTAINED 6 CARLISLE NEURO CARE 1 . ALL MEDICAL RECORDS IN YOUR POSSESSION. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PAIThNTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** RAINA MILLER, DOB Mat RECORDS FROM 1/1/2007 TO PRESENT. 2 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RAINA MILLER, DOB gin RECORDS FROM 1/1/2007 TO PRESENT. 7 HARRISBURG HOSPITAL 1 . ALL MEDICAL RECORDS INCLUDING INPATIENT, OUTPA I LENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RAINA MILLER, DOB NEM RECORDS FROM 1/1/2007 TO PRESENT. (MED) RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. RALPH CLAY HARRISBURG HOSPITAL RAD) TERM: DOCKET: 13-4018 1 . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE EE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING RTES OF STUDY PRIOR TO COPYING.** RAINA MILLER, DOB CORDS FROM 1/1/2007 TO PRESENT. Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: Date: FIRM: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: Page 2 RT: 262155.6 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE NEURO CARE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court c 1;1 12_6L Prothonotary '� t RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 6 LOCATION: CARLISLE NEURO CARE RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. * * * * * * * * * * * *PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** RAINA MILLER, DOB X/XX/XXXX RECORDS FROM X/X/XXXX TO PRESENT. X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RAINA MILLER, DOB X/XX/XXXX RECORDS FROM X/X/XXXX TO PRESENT. RT: 262155.7 • COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MIT I .F,R V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HARRISBURG HOSPI'� AL " ��e a (CQ.�4 �� COy'J (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoem together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing 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. HIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING- PERSON: Name: RecordTrak;'JOHN-LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800)220-1291 BY THE COURT: Supreme Court ID# ., Attorney for: Defendant DATE: Seal of the Court Prothonotary S i9C RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 7 LOCATION: HARRISBURG HOSPITAL (MED) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS INCLUDING INPATIENT, OUTPAI ENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RAINA MILLER, DOB X/XX/XXXX RECORDS FROM X/X/X)OX TO PRESENT. RT: 262155.8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HARRISBURG HOSPITAL — { Ida) Q u (Nam of/Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoen: together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: _ (804) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: Th, RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 8 LOCATION: HARRISBURG HOSPITAL (RAD) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * RAINA MILLER, DOB X/XX/XXXX RECORDS FROM X/X/XXXX TO PRESENT. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA RAINA M. MILLER vs. TERM: RALPH CLAY CASE No: 13-4018 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 06/11/2014 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant r CO Cf) r" cD • t RT#: 262155 RECORDS PERTAIN TO: RAINA MILLER RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. TERM: RALPH CLAY NOTICE TO: DENNIS J. SHATTO CLECKNER & FEAREN 119 LOCUST STREET P.O. BOX 11847 HARRISBURG, PA 17101 (717) 238-8481 May 1, 2014 : DOCKET: 13-4018 OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS Please take notice that on behalf of JOHN L UCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until May 21, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF PLAINTIFF'S COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY May 21, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN 9 KEYSTONE WOMEN'S CARE 10 CONCENTRA MEDICAL CENTER 11 CARLISLE REGIONAL MEDICAL CENTER (MED) 12 CARLISLE REGIONAL MEDICAL CENTER (RAD) 13 HOLY SPIRIT HOSPITAL (MED) 14 HOLY SPIRIT HOSPITAL (RAD) 15 PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) 16 PENN STATE MILTON S. HERSHEY MEDICAL CENTER (RAD) Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: FIRM: Date: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. : TERM: RALPH CLAY DOCKET: 13-4018 Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: Page 2 RT: 262155.9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: KEYSTONE WOMEN'S CARE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 1.9406 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 may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you tail 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1.291 Supreme Court ID# Attorney for: Defendant DATE; Seal of the Court BY THE COURT: 9 RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 9 LOCATION: KEYSTONE WOMEN'S CARE RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED XX/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH TIE RECORDS.************ X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * RT: 262155.10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No:13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CONCENTRA MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider, at /© 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or produdng the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court 11P /ir AM..f�.�1Ia.`ti ��th i of RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 10 LOCATION: CONCENTRA MEDICAL CENTER RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED XX/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 262155.11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or produdng 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: RccordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001220.1 91 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: -fL RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 11 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (MED) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/X/XXXX TO THE PRESENT INCLUDING INPATIENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 262155.12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TQ PRODUCE DOCUMENTS OR THINGS I'QR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this sabpoenu together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing 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; RccordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: 03001220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 12 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (RAD) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XXIXIXXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.* RT: 262155.13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MIT LER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR TIDINGS FOR DISCOVERY FURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (Name of Person or Eutity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fall to produce the documents or things required by this subpoena within twenty (20) days ate 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001 220-1291 BY THE COURT: Supreme Court ID# Attorney tor: Defendant DATE: Seal of the Court .S)1 RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 13 LOCATION: HOLY SPIRIT HOSPITAL (MED) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/X/XXXX TO THE PRESENT INCLUDING INPATIENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 262155.14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MITT .P,R V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCU $ NTS OR SING FO DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 13, of 65 I Allendale Road King of Prussia PA 19406 Von gray 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 may have the right to seek in advance the reasonable cost of preparing 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court S) RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 14 • LOCATION: HOLY SPIRIT HOSPITAL (RAD) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 262155.15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No; 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road Kin _ of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoeni together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court IDB Attorney for: Defendant DATE: 1 Seal of the Court BY THE COURT: RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 15 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS XX/X/XXXX TO PRESENT INCLUDING INPAI'1ENT, OUTPA HENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 262155.16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No; 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek In advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800)220-1291. Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court BY THE COURT: /ts RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 16 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (RAD) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * **COPY** CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA RAINA M. MILLER vs. TERM: RALPH CLAY CASE No: 13-4018 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 06/11/2014 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant RT#: 262155 RECORDS PERTAIN TO: RAINA MILLER RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. •TERM: : DOCKET: 13-4018 OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS RALPH CLAY NOTICE TO: DENNIS J. SHATTO CLECKNER & FEAREN 119 LOCUST STREET P.O. BOX 11847 HARRISBURG, PA 17101 (717) 238-8481 May 1, 2014 Please take notice that on behalf of JOHN L UCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until May 21, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF PLAINTIFF'S COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY May 21, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN 9 KEYSTONE WOMENS CARE 10 CONCENTRA MEDICAL CENTER 11 CARLISLE REGIONAL MEDICAL CENTER (MED) 12 CARLISLE REGIONAL MEDICAL CENTER (RAD) 13 HOLY SPIRIT HOSPITAL (MED) 14 HOLY SPIRIT HOSPITAL (RAD) 15 PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) 16 PENN STATE MILTON S. HERSHEY MEDICAL CENTER (RAD) Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: FIRM: Date: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. RALPH CLAY TERM: DOCKET: 13-4018 Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: Page 2 RT: 262155.9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: KEYSTONE WOMEN'S CARE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 inay have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days afte: 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE; Seal of the Court BY THE COURT: 9 RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 9 LOCATION: KEYSTONE WOMEN'S CARE RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED XX/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PA11hNTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************ X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 262155.10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No:13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CONCENTRA MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider, at /© 651 Allendale Road King of Prussia PA 19406 You may deliver or mail legible copies of the documents or produce things requested by this subpoen: together with the cerdflcate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or produdng the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 10 LOCATION: CONCENTRA MEDICAL CENTER RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED XX/X/XXXX TO THE PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** RT: 262155.11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400.22 TO: CARLISLE REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to product the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: rt, Seal of the Court BY THE COURT: RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 11 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (MED) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/X/XXXX TO THE PRESENT INCLUDING INPATIENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 262155.12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CARLISr .E REGIONAL MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at /I -1Z 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court 114 BY THE COURT: RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 12 LOCATION: CARLISLE REGIONAL MEDICAL CENTER (RAD) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XXIX/XXXX TO THE PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.* RT: 262155.13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY !'URSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or produdng the things sought If you fall to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001 220-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court sk) 1.4 RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 13 LOCATION: HOLY SPIRIT HOSPITAL (MED) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS DATED XX/X/XXXX TO THE PRESENT INCLUDING INPA1'EENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 262155.14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MITI .ER V. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY pURSUANT TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at f3,IY 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (8001 220-1291 BY THE COURT: Supreme Court IID Attorney for: Defendant DATE: Seal of the Court RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 14 LOCATION: HOLY SPIRIT HOSPITAL (RAD) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * RT: 262155.15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER v. RALPH CLAY File No: 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered b following documents or things: See attached rider, e Court to produce the 651 Allendale Road King of Prussia PA 19406 You inay 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 may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (80f» 220-1291 Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court S 62 1 lid) BY THE COURT: RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 15 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (MED) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS XX/X/XXXX TO PRESENT INCLUDING INPATIENT, OUTPATIENT AND EMERGENCY ROOM TREATMENT, ALL CLINICAL CHARTS, REPORTS, INCLUDING RADIOLOGY REPORTS AND PATHOLOGY REPORTS, DOCUMENTS, CORRESPONDENCE, TEST RESULTS, STATEMENTS, QUESTIONNAIRES/HISTORIES, AND RECORDS RECEIVED FROM OTHER PHYSICIANS. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. RT: 262155.16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No; 13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENN STATE MILTON S . HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days afte 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (SOP) 220-1291 Supreme Court ID* Attorney for: Defendant DATE: tu Lei Seal of the Court BY THE COURT: RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 16 LOCATION: PENN STATE MILTON S. HERSHEY MEDICAL CENTER (RAD) RECORDS PERTAIN TO: RAINA MILLER SS it: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED XX/X/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING.** CERTIFICATE 2014 rri PREREQUISITE TO SERVICE OF A SUBPOENA p&ERLAND ENNsYLVA yIUNTY PURSUANT TO RULE 4009.22 IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA RAINA M. MILLER vs. TERM: RALPH CLAY CASE No: 13-4018 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 08/13/2014 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant RT#: 262155 RECORDS PERTAIN TO: RAINA MILLER RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. •TERM: : DOCKET: 13-4018 OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS RALPH CLAY NOTICE TO: DENNIS J. SHATTO CLECKNER & FEAREN 119 LOCUST STREET P.O. BOX 11847 HARRISBURG, PA 17101 (717) 238-8481 July 23, 2014 Please take notice that on behalf of JOHN LUCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until August 12, 2014 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE CONES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY August 12, 2014 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG 21 RECORD CUSTODIAN CHAMBERSBURG HOSPITAL (RAD) Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: FIRM: Date: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: Date: FIRM: EMAIL: RT: 262155.21 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RAINA M. MILLER V. RALPH CLAY File No: 13-4018 SI,BPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CHAMBERSBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. 651 Allendale Road Kind; of Prussia PA 19406 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 may have the right to seek in advance the reasonable cost of preparing copies or produdug the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days atter 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: (800) 220-1291, Supreme Court ID# Attorney for: peferidant DATE: Seal of the Court BY THE COURT: Prothonotary ,eer RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 21 LOCATION: CHAMBERSBURG HOSPITAL (RAD) RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS. XX/X/XXXX TO PRESENT **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * * ***INCLUDING BUT NOT LIMITED TO RECORDS FROM KEYSTONE WOMENS CARE*** i‘e - (1G -(e D4--In orw )ois )j:f\ PAA tu-m\takx. \0;`,,, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RAINA M. MILLER vs. RALPH CLAY Court of Common Pleas - Cumberland County, PA TERM: CASE No: 13-4018 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22. RecordTrak on behalf of JOHN LUCY Defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) No objection to the subpoena has been received or it has been waived, and (3) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date : 01/07/2015 RecordTrak on behalf of /S/ JOHN LUCY Attorney for Defendant 3 RT#: 262155 RECORDS PERTAIN TO: RAINA MILLER RAINA M. MILLER COURT: Court Of Common Pleas - Cumberland County, Pa vs. : TERM: RALPH CLAY NOTICE TO: DENNIS J. SHATTO CLECKNER & FEAREN 119 LOCUST STREET P.O. BOX 11847 HARRISBURG, PA 17101 (717) 238-8481 December 15, 2014 DOCKET: 13-4018 OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS Please take notice that on behalf of JOHN LUCY, attorney for Defendant, RecordTrak intends to serve a subpoena identical to the one(s) attached to this notice. You have until January 5, 2015 to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection is made, the subpoena(s) will be served. IF COUNSEL AGREES TO WAIVE THE 20 DAY NOTICE PERIOD, PLEASE INDICATE BELOW AND FAX SAME TO THE UNDERSIGNED AT YOUR EARLIEST OPPORTUNITY. IF YOU WISH TO PURCHASE COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING AND FAX THIS CORRESPONDENCE BY January 5, 2015 TO (610) 992-1405. All records will be provided (including no record statements) as produced by each record location. Daniel Wake 610.354.8348 RECORDTRAK 651 Allendale Road P. O. Box 61591 King of Prussia, PA 19406 LIST OF RECORD CUSTODIANS AND SUBPOENAS TAG RECORD CUSTODIAN 24 WORKNET Yes, I would like a copy of all of the records listed above. Yes, I would like specific records I have indicated above. SIGNATURE: FIRM: Date: YES, I AGREE TO WAIVE THE 20 DAY NOTICE PERIOD FOR ALL SUBPOENAS ON THIS NOTICE Signature of Plaintiff's Counsel: FIRM: EMAIL: Date: RT: 262155.24 rip • P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MINA M. MILLER V. RALPH CLAY File No:13-4018 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WORKNET (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things: See attached rider. at 651 Allendale Road King of Prussia PA 19406 _ You may deliver or mail legible copies of the documents or produce things requested by this subpoen; together with the certificate of compliance, to the party making this request at the address listed above. You may have the right to seek in advance the reasonable cost of preparing copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days afte: 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: RecordTrak, JOHN LUCY Address: 651 Allendale Road King of Prussia PA 19406 Telephone: j80012.20-1291 BY THE COURT: Supreme Court ID# Attorney for: Defendant DATE: Seal of the Court RE: RAINA M. MILLER vs. RALPH CLAY CASE NO. 13-4018 RECORDTRAK FILE #: 262155; TAG 24 LOCATION: WORKNET RECORDS PERTAIN TO: RAINA MILLER SS #: , DOB: X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED FROM XX/X/XXXX TO PRESENT. INCLUDE OFFICE AND HAND WRITTEN NOTES, TEST RESULTS, CORRESPONDENCE, RADIOLOGY REPORTS, PATHOLOGY REPORTS, QUESTIONNAIRES/HISTORY & RECORDS RECEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PAIIhNTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE RECORDS.************** X . ALL X-RAYS, MRI SCANS, CT SCANS AND CORRESPONDING REPORTS DATED FROM XX/X/XXXX TO PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES; CD OR FILMS AND THE FEE FOR EACH. PLEASE PROVIDE AN INVENTORY OF ALL FILMS, INCLUDING DATES OF STUDY PRIOR TO COPYING. * *