HomeMy WebLinkAbout13-4487 Supreme Court of ,Pennsylvania
Cou't f C om 'on Pleas
,1�1V11:C r nee For Prothonotary Use Only:
CUMBERLAND -� County Docket No: Si
The information collecled on this form is used solely court adininistration purposes. This form does not
supplemenl or replace the filing and service of j9leadings or other papers as required by law or rules of court.
Commencement of Action:
S
El Complaint 0 Writ of Summons ❑ Petition El Notice of Appeal
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiffs Name: Lead Defendant's Name:
T Steven A. Ruby Shyamlata P. Patel
I ❑ Check here if you are a Self- Represented (Pro Se) Litigant
0 Name of Plaintiff /Appellant Attorney: Leslie M. Fields, Esqu Costopoulos, Fo ster & Fields, 83 1 M Str L PA 17043
N Dollar Amount Requested: within arbitration limits
Are money damages requested? : ❑X Yes ❑ No (Check one) X outside arbitration limits
A
Is this a Class Action Suit? ❑ Yes ❑O No
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑x Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Zoning Board
S ❑ Product Liability (does not include 11 Statutory Appeal: Other
mass tort) 11 Employment Dispute:
E Discrimination
❑ Slander/Libel/ Defamation
C El Other: El Employment Dispute: Other
Judicial Appeals
T ❑ MDJ - Landlord /Tenant
I ❑ Other: ❑ MDJ - Money Judgment
O MASS TORT ❑ Other:
❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
B
El Other: El Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure Restraining Order
PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto
❑ Dental ❑ Quiet Title ❑ Replevin
❑ Legal
❑ Medical ❑ Other: ❑ Other:
❑ Other Professional:
Pa.R.C.P. 205.5 212010
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Steven A. Ruby
305 Walnut Street � � �
Carlisle, PA 17015 Case No. `fi YO Civil Term
Erin Ruby
3 Redwood Court
Camp Hill, PA 17011
Civil Action
V.
Shyamlata P. Patel �•
47 Honeysuckle Avenuei� C-- _
Mechanicsburg, PA 17050 E_
y � r -.. 4
PRAECIPE FOR WRIT OF SUMMONS o - TIj
TO THE PROTHONOTARY /CLERK OF SAID COURT
Issue summons in the above case.
Writ of Summons shall be issued and forwarded to ZAft /Sh er iff.
Date:
ignatur of Attorney
Print Name: Leslie M. Fields, Esquire
Address: Costopoulos, Foster & Fields
831 Market Street
Lemoyne, PA 17043
Telephone #: 717- 761 -2121
Supreme Court ID Number: 29411 Q4tc`JQ3
• • • • •
WRIT OF SUMMONS
TO:
YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF(S) HAS /HAVE
COMMENCED AN ACTION AGAINST YOU.
Prothonotary/Clerk, Civil Division
Date: 3 J j3 - 1a
Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY:,
Ronny R Anderson - -;
Sheriff
� g
Jody S Smith
Chief Deputy
Richard W Stewart CD
Solicitor OPPICE OrTYE f<R1Fr � --
Steven A Ruby(et al.)
Case Number
vs.
Shyamalata P Patel 2413-4487
SHERIFF'S RETURN OF SERVICE
0810512013 07:53 PM- Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Writ of
Summons by handing a true copy to a person representing themselves to be Parvin Patel, Husband, who
accepted as"Adult Person in Charge"for Shyamalata P Patel at 47 Honeysuckle Avenue, Silver Spring,
Mechanicsburg, PA 17050.
JEF 'O L6DZI, D PUTY
SHERIFF COST: $45.41 SO ANSWERS,
August 06, 2013 RbNW R ANDERSON, SHERIFF
{c)COUNY,uiie Sheriff,Te!eosoR,Inc.
COSTOPOULOS,FOSTER&FIELDS
By: Leslie M.Fields,Esquire p
I.D.No.: 29411 :�.,A ` D COUNTY
831 Market Street,P.O.Box 222
Lemoyne,PA 17043-0222
Tel: 717.761.2121
Fax:717.761.4031
Email: Lfields(&Costopoulos.com
STEVEN A. RUBY and ERIN RUBY, : IN THE COURT OF COMMON PLEAS
HIS WIFE, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. No. 2013-4487
SITYAMLATA P. PATEL, CIVIL ACTION-LAW
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(s). 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:
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE,PA 17013
PHONE: (717)249-3166 OR(800) 990-9108
t
STEVEN A. RUBY and ERIN RUBY, IN THE COURT OF COMMON PLEAS
HIS WIFE, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V. No. 2013-4487
SITYAMLATA P. PATEL, CIVIL ACTION - LAW
Defendant JURY TRIAL DEMANDED
PLAINTIFFS' COMPLAINT
AND NOW come the Plaintiffs, Steven A. Ruby and Erin Ruby, his wife, by and through
their attorney, Leslie M. Fields, Esquire, COSTOPOULOS, FOSTER&FIELDS, and
respectfully represent as follows in support of this Complaint:
The Parties
1. Plaintiff, Steven A. Ruby, is an adult individual residing at 305 Walnut Lane, Carlisle,
Cumberland County, Pennsylvania 17015.
2. Plaintiff, Erin Ruby, is an adult individual residing at 3 Redwood Court, Camp Hill,
Cumberland County, Pennsylvania 17011.
3. Defendant, Shyamlata P. Patel, is an adult individual residing at 47 Honeysuckle
Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050.
Background Alleizations
4. The events giving rise to this cause of action occurred approximately at 11:12 p.m. on
or about October 6, 2011 while Plaintiff, Steven A. Ruby, was traveling in his motor vehicle on
East Main Street(State Route 641)near the intersection with South Chestnut Street in the
Borough of Mechanicsburg, Cumberland County, Pennsylvania.
5. At the aforesaid time and place, Plaintiff, Steven A. Ruby, was operating a 2002
Pontiac Sunfire automobile and traveling eastbound on East Main Street when Defendant,
Shyamlata P. Patel, who was operating a 2002 Toyota Sequoia SUV and traveling westbound on
East Main Street, crossed over into the Plaintiff's lane of traffic and struck the Plaintiff's vehicle
head-on, thereby causing the serious injuries and damages set forth in detail below.
6. As a direct and proximate result of the negligence, carelessness and/or recklessness of
the Defendant, Shyamlata P. Patel, the Plaintiff, Steven A. Ruby, has suffered serious injuries
and damages which are set forth in detail below.
7. The negligence, carelessness and/or recklessness of the Defendant, Shyamlata P. Patel,
was a substantial factor in causing the serious injuries and damages to the Plaintiff, Steven A.
Ruby, which are set forth in detail below.
COUNT I: NEGLIGENCE
Plaintiff Steven A. Ruby v. Defendant Shyamlata P. Patel
8. The allegations set forth in paragraphs 1 through 7 above are incorporated by reference
herein as if set forth in full.
9. At the aforesaid time and place, the collision and injuries resulting therefrom were
caused by the negligent, careless and/or reckless acts of the Defendant, Shyamlata P. Patel, in
that she:
a) operated her motor vehicle in careless disregard for the safety of persons
and property,particularly the Plaintiff, Steven A. Ruby, and his passengers and
vehicle;
b)violated Section 3714(a) of the Pennsylvania Motor Vehicle Code, 75
Pa.C.S. § 3714(a), "Careless driving; General rule," and thus is negligent per se;
c) caused the serious bodily injury of another person, specifically, Plaintiff,
Steven A. Ruby, as a result of the violation of Section 3714(a) of the Pennsylvania
-2-
Motor Vehicle Code;
d) violated Section 3714[c] of the Pennsylvania Motor Vehicle Code, 75
Pa.C.S. § 3714[c], "Careless driving; Serious bodily injury," and thus is negligent
per se;
e) drove carelessly;
f) engaged in distracted driving;
g) failed to notice that the Plaintiff's vehicle was in the opposing lane of
traffic;
h) failed to maintain her vehicle under proper and lawful control;
i) failed to keep a proper lookout;
j) failed to pay sufficient attention to the roadway and traffic;
k) failed to see what she should have seen;
1) failed to notice the imminence of an accident and take the necessary
steps to avoid it; and
m) acted without due regard for the safety and rights of other motorists,
including the Plaintiff, Steven A. Ruby.
10. As a direct and proximate result of the negligent, careless and/or reckless acts of the
Defendant, Shyamlata P. Patel, the Plaintiff, Steven A. Ruby, has suffered injuries which were
and are severe, painful, serious and permanent. These injuries include but are not limited to:
a) a severe contusion of the head;
b) a severe neck strain and sprain;
c) a serious concussion of the head;
d) a cerebrovascular accident(CVA);
-3-
e) explosive personality disorder;
f)post-concussion syndrome including but not limited to hemiplegic
migraines, headaches, dizziness, seizures, blurred vision, memory problems, left-
sided weakness, and episodes of unresponsiveness; and
g) cervicalgia.
11. As a further direct and proximate result of the negligent, careless and/or reckless acts
of the Defendant, Shyamlata P. Patel, the Plaintiff, Steven A. Ruby, has been obligated to receive
and undergo medical treatment and care and to assume medical expenses for the injuries he has
suffered, and may be obligated to continue to receive and undergo such medical treatment and
care and to assume medical expenses in the future.
12. As a further direct and proximate result of the negligent, careless and/or reckless acts
of the Defendant, Shyamlata P. Patel,the Plaintiff, Steven A. Ruby, has a sustained a loss of
earnings and a loss of earnings capacity, and may continue to sustain such loss of earnings and
loss of earnings capacity in the future.
13. As a further direct and proximate result of the negligent, careless and/or reckless acts
of the Defendant, Shyamlata P. Patel,the Plaintiff, Steven A. Ruby, has suffered medically
determinable physical impairments which have prevented him from performing all of the normal
acts and duties which constitute his usual and customary daily activities, and may continue to
suffer such medically determinable physical impairments in the future.
14. As a further direct and proximate result of the negligent, careless and/or reckless acts
of the Defendant, Shyamlata P. Patel,the Plaintiff, Steven A. Ruby, has experienced severe pain
and suffering, mental anguish and humiliation, and may continue to experience such severe pain
-4-
and suffering, mental anguish and humiliation in the future.
15. As a further direct and proximate result of the negligent, careless and/or reckless acts
of the Defendant, Shyamlata P. Patel, the Plaintiff, Steven A. Ruby, has suffered a loss of life's
pleasures, and may continue to suffer such a loss of life's pleasures in the future.
16. As a further direct and proximate result of the negligent, careless and/or reckless acts
of the Defendant, Shyamlata P. Patel,the Plaintiff, Steven A. Ruby, has sustained certain
incidental costs, and may continue to sustain such certain incidental costs in the future.
COUNT II: LOSS OF CONSORTIUM
Plaintiff Erin Ruby v. Defendant Shvamlata P. Patel
17. The allegations set forth in paragraphs 1 through 16 above are incorporated by
reference herein as if set forth in full.
18. At all relevant times herein,the Plaintiff, Erin Ruby, and the Plaintiff, Steven A.
Ruby, were lawfully and continuously married, although they are currently living apart.
19. As a direct and proximate result of the negligent, careless and/or reckless acts of the
Defendant, Shyamlata P. Patel, the Plaintiff, Erin Ruby, has sustained a loss of consortium,
society and companionship of her husband, the Plaintiff, Steven A. Ruby, and may continue to
sustain such loss in the future.
Conclusion
WHEREFORE, Plaintiffs, Steven A. Ruby and Erin Ruby, his wife, based on the
foregoing averments, hereby demand judgment in their favor and against Defendant, Shyamlata
P. Patel, in an amount in excess of the compulsory arbitration limits together with costs and
-5-
interest as provided by law.
RESPECTFULLY SUBMITTED:
eslie M. ields, Esquire
I.D. No. 29411
COSTOPOULOS, FOSTER& FIELDS
831 Market Street/P.O. Box 222
Lemoyne, Pennsylvania 17043
Phone: 717.761.2121
Fax: 717.761.4031
Email: Lfields@Costopoulos.com
Web: www.Costopoulos.com
ATTORNEY FOR PLAINTIFFS
DATED: November 14, 2013
-6-
VERIFICATION
I, Plaintiff, Steven A. Ruby, do hereby verify that the facts set forth in the foregoing
document are true and correct to the best of my knowledge, information and belief. I understand
that this statement is made subject to the penalties at 18 Pa.C.S. § 4904 relating to unsworn
falsification to authorities.
BY:
Steven A. Ruby
DATED: July �1 , 2013.
-7-
VERIFICATION
I, PlaintilT Erin Ruby, do hereby verify that the facts set forth in the foregoing document
are true and correct to the best of my knowledge, information and belief. I understand that this
statement is made subject to the penalties at 18 Pa.C.S. § 4904 relating to unworn falsification
to authorities.
BY:
Erin Ruby
DATED: / , 2013.
-8-
"014 JA, 1 P t;
U1°18E, 2• �`'
JDENj S YL ANIA
ANT a!
Johnson, Duffie, Stewart &Weidner
BY: John A. Lucy, Esquire
I.D. No. 203948 Attorneys for Defendant,
301 Market Street Shyamlata P. Patel
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
jai @jdsw.com
STEVEN A. RUBY and ERIN RUBY, IN THE COURT OF COMMON PLEAS OF
his wife, CUMBERLAND COUNTY,
Plaintiffs PENNSYLVANIA
V. NO. 2013-4487
SITYAMLATA P. PATEL, CIVIL ACTION — LAW
Defendant
JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance as counsel for Defen nt, Sh amlata P. Patel, in
the above-captioned matter.
JOHNSON UFFIE, EWA WEIDNER
BY:
x7) 761-4540, Esquire
No. 203948
treet, P.O. Box 109
17043-0109
jal @jdsw.com
Counsel for Defendant,
Date: January 2014 Shyamlata P. Patel
600722
r
CERTIFICA'rE 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 and unrepresented
parties by depositing the same in the United States First Class Mail, postage prepaid, in
Lemoyne, Pennsylvania, on January b, 2014, as follows:
Leslie M. Fields, Esquire
Costopoulos, Foster & Fields
831 Market Street
P.O. Box 222
Lemoyne, PA 17043-0222
Counsel for Plaintiffs
JO SON, DUF E, WART & WEIDNER
B
oh A. Lucy
600722
• 4
riuNOTARY
CERTIFICATE t LI 20 Pr 2: v l
PREREQUISITE TO SERVICE OF A SUBPOWNs yL 'A h+1U
PURSUANT TO RULE 4009.22
IN THE MAIlER OF: Court of Common Pleas-Cumberland County,PA
STEVEN A.RUBY AND ERIN RUBY
vs. TERM:
SHYAMLATA P.PATEL
CASE No: 2013-4487
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 : 02/14/2014 ••
RecordTrak on behalf of
/S/JOHN LUCY
' Attorney for Defendant
•
V k r n
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RT#: 262073
RECORDS PERTAIN TO: STEVEN A. RUBY
STEVEN A. RUBY AND ERIN RUBY •• COURT: Court Of Common Pleas-Cumberland County,Pa
vs. • TERM:
SHYAMLATA P.PATEL : DOCKET: 2013-4487
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS
TO: LESLIE FIELDS,ESQUIRE
COSTOPOULOS,FOSTER&FIELDS
831 MARKET STREET
LEMOYNE,PA 17042
January 27, 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 18, 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 18,2014 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
1 CARLISLE NEURO CARE 1 .ANY AND ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-
- 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.**************2.ALL X-RAYS,MRI SCANS,CT SCANS
AND CORRESPONDING REPORTS FROM 10/6/01-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.**
2 HOLY SPIRIT HOSPITAL 1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-PRESENT.
(BEHAV FILTH)(MED) INCLUDE OFFICE AND HAND WRITTEN NOTES,TEST RESULTS,
CORRESPONDENCE,QUESTIONNAIRES/HISTORY&RECORDS RECEIVED BY
OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PA IIENTS 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.**************
***INCLUDING BUT NOT LIMITED TO RECORDS FOR HOLY SPIRIT •
BEHAVIORAL HEALTH***
•
STEVEN A. RUBY AND ERIN RUBY • COURT: Court Of Common Pleas-
Cumberland County,Pa
vs. : TERM:
SHYAMLATA P.PATEL : DOCKET: 2013-4487
4 SILVER CREEK FAMILY 1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-PRESENT.
I I ALTH CENTER 11 CLUDING BUT NOT LIMITED TO OFFICE AND HAND WRITTEN NOTES,TEST
I' SULTS,CORRESPONDENCE,QUESTIONNAIRES/HISTORY&RECORDS
I' CEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS
II ORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED
I• CORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE
SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE
I CORDS.**************2.ALL X-RAYS,MRI SCANS,CT SCANS AND
ORRESPONDING REPORTS FROM 10/6/01-PRESENT. **PLEASE INCLUDE THE
I ORMAT FOR THE COPIES;CD OR FILMS AND THE FEE FOR EACH.PLEASE
I•ROVIDE AN INVENTORY OF ALL FILMS,INCLUDING DATES OF STUDY PRIOR
O COPYING.**
5 PENNSYLVANIA 1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-PRESENT.
I'SYCHIATRIC INSTITUTE 11 CLUDING BUT NOT LIMITED TO OFFICE AND HAND WRITTEN NOTES,TEST
I SULTS,CORRESPONDENCE,QUESTIONNAIRES/HISTORY&RECORDS
I' CEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS
II ORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED
I' CORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE
SIGN THE ATTACHED CER I I FICATION AND RETURN WITH THE •
I' CORDS.**************
• 6 YORK HOSPITAL*PA 1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-PRESENT.
•
LLSPAN HEALTH(MED) II CLUDING BUT NOT LIMITED TO OFFICE AND HAND WRITTEN NOTES,TEST
I' SULTS,CORRESPONDENCE,QUESTIONNAIRES/HISTORY&RECORDS
I• 'CEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PATIENTS
II ORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED
I' _CORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE -`
SIGN THE ATTACHED CERTIFICATION AND RETURN WITH THE
I' CORDS.**************
7 YORK HOSPITAL*PA I .ALL X-RAYS,MRI SCANS,CT SCANS AND CORRESPONDING REPORTS FROM
LLSPAN HEALTH(RAD) 10/6/01-PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES;CD OR
I ILMS AND THE FEE FOR EACH.PLEASE PROVIDE AN INVENTORY OF ALL. -
I ILMS,INCLUDING DATES OF STUDY PRIOR TO COPYING.** .
9 HOLY SPIRIT HOSPITAL 1 .ALL X-RAYS,MRI SCANS,CT SCANS AND CORRESPONDING REPORTS FROM
RAD) 10/6/01-PRESENT. **PLEASE INCLUDE THE FORMAT FOR THE COPIES;CD OR
I ILMS AND THE FEE FOR EACH.PLEASE PROVIDE AN INVENTORY OF ALL
I ILMS,INCLUDING DATES OF STUDY PRIOR TO COPYING.**
.• 10 GIANT FOOD STORES*PA 1 .ANY AND ALL EMPLOYMENT RECORDS FROM 10/6/01-PRESENT., .
*CORP II CLUDING,BUT NOT LIMITED TO: PERSONNEL RECORDS,JOB
•PLICATIONS,HIRING DOCUMENTATION,PAY RATE,HOURS WORKED,
I' _VIEWS,DISCIPLINARY ACTIONS,EXIT/TERMINATION DOCUMENTATION.
11 PENN STATE MILTON S. 1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-PRESENT. .
I I RSHEY MEDICAL CENTER II CLUDING BUT NOT LIMITED TO OFFICE AND IIAND WRITTEN NOTES,TEST
MED) 1• SULTS,CORRESPONDENCE,QUESTIONNAIRES/HISTORY&RECORDS
• , -
CEIVED BY OTHER PHYSICIANS. PLEASE ALSO INCLUDE THE PAIII?NTS .."
II ORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED
I' CORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE '
IGN THE ATTACHED CERTIFICATION AND RETURN WITH THE
•
1. CORDS.**************
12 PENN STATE MILTON S. 1.ALL X-RAYS,MRI SCANS,CT SCANS AND CORRESPONDING REPORTS. • •
I I RSHEY MEDICAL CENTER **PLEASE INCLUDE THE FORMAT FOR THE COPIES;CD OR FILMS AND THE •
• • • RAD) I EE FOR EACH.PLEASE PROVIDE AN INVENTORY OF ALL FILMS,INCLUDING
DATES OF STUDY PRIOR TO COPYING.**
Yes, I would like a copy of all of the records listed above. .
Yes, I would like specific records I have indicated above.
t. j4r1
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STEVEN A.RUBY AND ERIN RUBY • COURT: Court Of Common Pleas-
Cumberland County,Pa
vs. : TERM:
SHYAMLATA P.PATEL : DOCKET: 2013-4487
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:
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Page 3
RT: 262073.1
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A. RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No:2013-4487
SUBPOENA TO PRODUCE D9CUMENTS 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 subpoens
together with the certificate of compliance, to the party maldng 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:RccordTrakt JOHN LUCY
Address: 651 Allendale Road King of Prussia PA 19406
Telephone: (80Q)22Q-.291 BY THE COURT: •. .
Supreme Court ID#
•
•
Attorney for Def '. f.. y ' f
•
r j�
ti
DATE: -�h ? 6 tf,'
A •.. . 7 • • Em• 41 al..C■2 CIF:44 1142: •
•
•
Prothonotary
Seal of the Court
RE: STEVEN A. RUBY AND ERIN RUBY vs. SITYAMLATA P.PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 1
LOCATION: CARLISLE NEURO CARE
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1 .ANY AND ALL MEDICAL RECORDS IN YOUR POSSESSION FROM
10/6/01-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
PA IIENTS INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED
RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE
SIGN THE ATTACHED CER•I'IFICATION AND RETURN WITH THE
RECORDS.**************
2 .ALL X-RAYS,MRI SCANS,CT SCANS AND CORRESPONDING REPORTS FROM
10/6/01-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.**
•
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RT: 262073.2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A,RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No:2013-4487
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
• 651 Allendale Road King of Prussia PA 19406 .' • •
You may deliver or mar.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: r
Name:RccordTrak, JOHN LUCY ; {• - --
Address: 651 Allendale Road King of Prussia PA 19406
• V Telephone: (800)22R-\1,291'••'•-•. BY THE COURT:
Supreme Court ID# ,r_,
. Attorney for Defy - # 1
�. ;•"'*_ ti.�___ Prothonotary
DATE: ViN'"
•
Seal of the Court
•
•
RE: STEVEN A.RUBY AND ERIN RUBY vs. SHYAMLATA P.PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 2
LOCATION:HOLY SPIRIT HOSPITAL(BEHAV HLTH)(MED)
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-PRESENT.
INCLUDE 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.**************
***INCLUDING BUT NOT LIMITED TO RECORDS FOR HOLY SPIRIT BEHAVIORAL
HEALTH***
v Y •
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RT: 262073.4
•
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A.RUBY AND ERIN RUBY
V.
SHYAMLATA P.PATEL
File No:2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PUR§UANT TO RULE 4009.22
TO: SILVER CREEK FAMILY HEALTH 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 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 produdng the things sought. •
If you fail to produce the documents or things requireil'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:Dif dao :
f f •
•
. •. "t - ' Prothonotary .
DATE: '' � �• .•
Seal of the Court -'
•
RE: STEVEN A.RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 4
LOCATION: SILVER CREEK FAMILY HEALTH CENTER
RECORDS PERTAIN TO: STEVEN A.RUBY SS#: ,DOB:
1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-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 PA VENTS 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.**************
2.ALL X-RAYS,MRI SCANS,CT SCANS AND CORRESPONDING REPORTS FROM
10/6/01-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.**
1.rr.
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RT: 262073.5
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A.RUBY AND ERIN RUBY
V.
SHYAMLATA P.PATEL
File No:2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO:PENNSYLVANIA PSYCHIATRIC INSTITUTE -
(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 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: (SOOT , r,"'- BY THE COURT:
Supreme Court ID.K. ^
Attorney for:_rt { I '1
V,I;• _`^ , Prothonotary
DATE: ' =' � "D - ; _ •
�`"f+•ry -mss. I .
Seal of the Court
•
RE: STEVEN A.RUBY AND ERIN RUBY vs. SHYAMLATA P.PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 5
LOCATION:PENNSYLVANIA PSYCHIATRIC INSTITUTE
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-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.**************
•
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P.71
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1 i 4' i
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RT: 262073.6
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A.RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
i
File No:2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY,
PURSUANT TO RULE 4009.0
TO:YORK HOSPITAL * PA WELLSPAN HEALTH
(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 DeArasa f,�. �
_ Prothonotary
DATE:
•
Seal of the Court
•
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P.PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 6
LOCATION: YORK HOSPITAL*PA WELLSPAN HEALTH(MED)
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-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.**************
•
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RT: 262073.7
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A.RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No:2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.Za
.. TO:YORK HOSPITAL *PA WELLSPAN HEALTH
,'.:. (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 fall to produce the documents or things required by this subpoena within twenty(20)days aftt • ,,
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) 2204291 BY THE COURT:
Supreme Court ID#. . • • .. F
Attorney for - ,
Prothonotary - •
. . DATE: ,,�j
•
Seal of the Court
•
•
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P.PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 7
LOCATION: YORK HOSPITAL*PA WELLSPAN HEALTH(RAD)
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1 .ALL X-RAYS,MRI SCANS,CT SCANS AND CORRESPONDING REPORTS FROM
10/6/01-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.**
•
•
•
•
• .I
RT: 262073.9
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
•
STEVEN A.RUBY AND ERIN RUBY
V.
SITYAMLATA P. PATEL
File No:2013-4487
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
1
651 Allendale Road King of Prussia PA 19406
You may deliver or main,legible copies of the documents or produce things requested by this snbpoen: •
• 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:RccordTrak, JOHN LUCY _
Address: 651 Allendale Road King of Prussia PA 19406
' Telephone: (800)22((291.'''••••. BY TIIE COURT: •
Supreme Court ID# ,` ,=�
Attorney for Def '. �; .��^�1 ^ �-� • t { .
`'�,•r ��.^ - Prothonotary
• DATE: , �.�
•
Seal of the Court
1 . -
•
RE: STEVEN A.RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 9
LOCATION: HOLY SPIRIT HOSPITAL(RAD)
RECORDS PERTAIN TO: STEVEN A.RUBY SS#: ,DOB:
1 .ALL X-RAYS,MRI SCANS,CT SCANS AND CORRESPONDING REPORTS FROM
10/6/01-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: 262073.10
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A.RUBY AND ERIN RUBY
V.
SHYAMLATA P.PATEL
File No:2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO:GIANT FOOD STORES *PA *CORP
(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,301-IN LUCY
Address: 651 Allendale Road King of Prussia PA 19406
•
•
Telephone: (800) 22p;12' ' ,., _ BY THE COURT:Supreme Court ID# ��1 r_ .. -
Attorney for:Defen 1^.' •^`•
.i Prothonotary
*• DATE: .1 It-4W( _
Seal of the Court M.
RE: STEVEN A.RUBY AND ERIN RUBY vs. SHYAMLATA P.PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#:262073; TAG 10
LOCATION: GIANT FOOD STORES*PA*CORP
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1 .ANY AND ALL EMPLOYMENT RECORDS FROM 10/6/01-PRESENT. INCLUDING,
BUT NOT LIMITED TO: PERSONNEL RECORDS,JOB APPLICATIONS,HIRING
DOCUMENTATION,PAY RATE,HOURS WORKED,REVIEWS,DISCIPLINARY
ACTIONS,EXIT/TERMINATION DOCUMENTATION.
•
•
•
•
•
••
• •
•
• 4
•1
•
•
I
1
RT: 262073.11
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A.RUBY AND ERIN RUBY '
1
V. i
SHYAMLATA P. PATEL i
i
i
File No:2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO:PENN STATE MILTON S.HERSHEY MEDICAL CENTER • •µ
(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 subpooeui
together with the certificate of compliance,to the party malting this request at the address listed above. You
may have the light to seek in advance the reasonable cost of preparing copies or produdng the things sought,
i 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]9 RSON:
Name:RccordTrak,JOHN LUCY
.'`, Address: 651 Allendale Road King of Prussia PA 19406 • '
Telephone: (8001 22 -1,291.. BY THE COURT: . •
I. Supreme Court II)# �. •- _
Attorney for:De tdenf y, ..„ -`' i .••- 0.-"-7,.....'..%,
'-f, ';w ".:,.\..-.. ∎,,. Prothonotary • ... /100e041•1•11161 •
• DATE 1 �7�[f (' ,.�.,,` '
a
' Seal of the Court
sA
!t
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 11
LOCATION: PENN STATE MILTON S.HERSHEY MEDICAL CENTER(MED)
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1 .ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/01-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.**************
t
P `
P
•
v.
•
.
RT: 262073.12
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A.RUBY AND ERIN RUBY
V. '.
SITYAMLATA P.PATEL
File No:2013-4487
SUBPOENA TO P:ZODUCE 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 subpoetm
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: (8001220-1x291.. BY THE COURT:
' Supreme Court II3ii �� '. -
Attorney for:Deaf
! 414•e ''; ✓r; �,, - Prothonotary 6
DATE:
' •
Seal of the Court
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE#: 262073; TAG 12
LOCATION:PENN STATE MILTON S.HERSHEY MEDICAL CENTER(RAD)
RECORDS PERTAIN TO: STEVEN A. RUBY SS#: ,DOB:
1.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.**
•
•
r, •
•
•
•
•
•
r a �
Johnson, Duffie, Stewart & Weidner
BY: John A. Lucy, Esquire
I.D. No. 203948
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043 -0109
(717) 761 -4540
jal @jdsw.com
STEVEN A. RUBY and ERIN RUBY,
his wife,
Plaintiffs
v.
SHYAMLATA P. PATEL,
Defendant
P/1 1: 35
toUMBFRLAtND COUNTY
PENN S''LVA NIA
Attorneys for Defendant,
Shyamlata P. Patel
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
•
NO. 2013 -4487
•
CIVIL ACTION — LAW
•
•
JURY TRIAL DEMANDED
STIPULATION OF COUNSEL
It is hereby stipulated by and between John A. Lucy, Esquire, counsel for
Defendant, and Leslie M. Fields, Esquire, counsel for Plaintiffs, that the terms
"recklessness" in Paragraphs 6 and 7 and "reckless" in Paragraphs 9, 10, 11, 12, 13,
14, 15, 16, and 19 are hereby stricken from the Complaint.
COSTOPOULOS, FOSTER & JOHNSON, DUF IE, STEWART &
FIELDS WEIDN R
BY
Date:
600739
Leslie M. Fields, Esquire
Attorne I.D. No. 29411
831 Market Street
P.O. Box 222
Lemoyne, PA 17043 -0222
761 -2121
Lfields @Costopoulos.com
Counsel for Plain'
tiff
1 i2��-
BY:
John . Lucy, Esquire
Atto ey I.D. No. 203948
301 Market Street, P.O. Box 109
Lemoyne, PA 17043 -0109
761 -4540
jal @jdsw.com
Counsel for Defendant
Date:
?,1 a •- ( 2 a (--/
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Stipulation of
Counsel has been duly served upon all counsel of record and unrepresented parties by
depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne,
Pennsylvania, on 'cu.x.clik., Y, 2014, as follows:
Leslie M. Fields, Esquire
Costopoulos, Foster & Fields
831 Market Street
P.O. Box 222
Lemoyne, PA 17043-0222
Counsel for Plaintiffs
JOHNSON, DUFFIE, STEWART & WEIDNER
BY:
n A. Lucy
600739
2111fi MAR 28 Plc 1: 38
Cli-MBERLII,NO COUNTY
PENNSYLVANIA,
Johnson, Duffie, Stewart & Weidner
BY: John A. Lucy, Esquire
I.D. No. 203948
301 Market Street, P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
jal@jdsw.com
STEVEN A. RUBY and ERIN RUBY,
his wife,
Plaintiffs
v.
Attorneys for Defendant,
Shyamlata P. Patel
• IN THE COURT OF COMMON PLEAS OF
• CUMBERLAND COUNTY,
• PENNSYLVANIA
• • NO, 2013-4487
• CIVIL ACTION — LAW
SHYAMLATA P. PATEL,
Defendant JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: Plaintiffs c/o Leslie M. Fields, Esquire
Costopoulos, Foster & Fields
831 Market Street
P.O. Box 222
Lemoyne, PA 17043-0222
AND NOW, this 27th day of March, 201
responsively within twenty (20) days of the dat
entered against you.
JOH
BY:
, you
service
re hereby notified to plead
ereof, or judgment may be
SON, DUFF
E, ST ART & WEIDNER
Jo n A. ucy, Esquire
A orn I.D. No. 203948
3J1 arket Street, P.O. Box 109
yne, PA 17043-0109
( ) 761-4540
jal@jdsw.com
Counsel for Defendant,
Shyamlata P. Patel
Johnson, Duffie, Stewart & Weidner
BY: John A. Lucy, Esquire
I.D. No. 203948
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043 -0109
(717) 761 -4540
jal @jdsw.com
STEVEN A. RUBY and ERIN RUBY,
his wife,
Plaintiffs
Attorneys for Defendant,
Shyamlata P. Patel
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v. : NO. 2013 -4487
: CIVIL ACTION — LAW
SHYAMLATA P. PATEL,
Defendant JURY TRIAL DEMANDED
ANSWER AND NEW MATTER OF DEFENDANT,
SHYAMLATA P. PATEL, TO PLAINTIFFS' COMPLAINT
AND NOW, comes Defendant, Shyamlata P. Patel, by and through his counsel,
John A. Lucy, Esquire and Johnson, Duffie, Stewart & Weidner, P.C., and files the
following Answer and New Matter to Plaintiffs' Complaint.
The Parties
1. Admitted upon information and belief.
2. Admitted upon information and belief.
3. Admitted.
Background Allegations
4. Admitted. It is admitted that this accident 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.
5. Admitted in part; denied in part. It is admitted that the vehicle being driven
by Steven A. Ruby was a 2002 Pontiac Sunfire automobile and that he was driving
eastbound on East Main Street when Defendant, who was operating a 2002 Toyota
Sequoia SUV was driving westbound on East Main Street and crossed over into the
Plaintiff's lane of travel, and a collision occurred. As to the remaining allegations, they
are hereby denied pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is
demanded at the time of trial.
6. Paragraph 6 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.
7. Paragraph 7 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.
COUNT I: NEGLIGENCE
Plaintiff, Steven A. Ruby v. Defendant, Shyamlata P. Patel
8. Defendant incorporates herein by reference his answers to Paragraphs 1
through 8 above as though fully set forth herein at length.
611793
9. (a) - (m). Paragraph 9 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.
10. (a) — (g). Paragraph 10 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.
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.
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.
13. Paragraph 13 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.
14. Paragraph 14 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.
15. Paragraph 15 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.
611793 3
16. Paragraph 16 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.
COUNT II: LOSS OF CONSORTIUM
Plaintiff, Erin Ruby v. Defendant, Shyamlata P. Patel
17. Defendant incorporates herein by reference his answers to Paragraphs 1
through 16 above as though fully set forth herein at length.
18. After reasonable investigation, Defendant is without knowledge or
information to form a belief as to the truth or falsity of the averments contained in
Paragraph 18 and the same is therefore denied and strict proof is demanded at the time
of trial.
19. Paragraph 19 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.
Conclusion
WHEREFORE, Defendant, Shyamlata P. Patel, respectfully requests that
judgment be entered in his favor and that Plaintiffs' Complaint be dismissed with
prejudice.
NEW MATTER
20. That Plaintiffs' alleged cause of action may be barred in whole or in part
by the Pennsylvania Motor Vehicle Financial Responsibility Law.
21. That Plaintiffs' alleged cause of action may be barred by the Pennsylvania
Motor Vehicle Financial Responsibility Law and the limited tort option.
611793 4
22. That Plaintiffs' alleged cause of action may be barred in whole or in part
by the applicable statute of limitations.
23. That the Plaintiffs' alleged cause of action may be barred in whole or in
part by the Plaintiffs own comparative negligence and the Pennsylvania Comparative
Negligence Act.
24. That if it should be found that there is any negligence on the part of
Mr. Patel, which is denied, then in that event, any such negligence is not a factual cause
of Plaintiffs harm.
25. That Plaintiff's alleged injuries may have been pre- existing.
26. That Plaintiffs may have failed to mitigate their alleged injuries.
27. That Plaintiffs' alleged cause of action may have been caused in whole or
in part by third parties or entities not presently involved in this action.
28. The accident may have been the result of a medical emergency.
WHEREFORE, Defendant, Shyamlata P. Patel, respectfully requests that
judgment be entered in his favor and that Plaintiffs' omplaint be dismissed with
prejudice.
Date: March 27, 2014
Re ?pectfully submitte
JOHNSON, DUFF , STE - 'T & WEIDNER
BY:
611793 5
John A, ucy, Esquire
Attor y I.D. No. 203948
301 arket Street, P.O. Box 109
Lemoyne, PA 17043 -0109
(717) 761 -4540
jaI @jdsw.com
Counsel for Defendant,
Shyamlata P. Patel
VERIFICATION
1, Shyamlata P. Patel, hereby acknowledge that I am the Defendant in this action;
that 1 have read the foregoing Answer and New Matter to Plaintiffs' Complaint; and
that the facts stated therein are true and correct to the best of my knowledge,
information and belief.
1 understand that any false statements herein are made subject to penalties of 18
Pa. C.S.A. §4904, relating to unsworn falsification to authorities.
Shyamlata P. Patel
Dated: 3 4/, 2014
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Answer and New
Matter to Plaintiffs' Complaint has been duly served upon all counsel of record and
unrepresented parties by depositing the same in the United States First Class Mail,
postage prepaid, in Lemoyne, Pennsylvania, on March 27, 2014, as follows:
Leslie M. Fields, Esquire
Costopoulos, Foster & Fields
831 Market Street
P.O. Box 222
Lemoyne, PA 17043 -0222
Counsel for Plaintiffs
OHNSON, DUFFIE STEWART & WEIDNER
BY:
John A.
STEVEN A. RUBY and ERIN RUBY, : IN THE COURT OF COMMON PLEAS
HIS WIFE, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v. : No. 2013- 4487
SHYAMLATA P. PATEL,
CIVIL ACTION - LAW
Defendant : JURY TRIAL DEMANDED
PLAINTIFFS' REPLY TO NEW MATTER
1,0 r
20. This paragraph constitutes a conclusion of law to which no response i5;iuir5d.
21. This paragraph constitutes a conclusion of law to which no response is required.
22. This paragraph constitutes a conclusion of law to which no response is required.
23. This paragraph constitutes a conclusion of law to which no response is required.
24. This paragraph constitutes a conclusion of law to which no response is required.
25. This paragraph constitutes a conclusion of law to which no response is required.
26. This paragraph constitutes a conclusion of law to which no response is required.
27. This paragraph constitutes a conclusion of law to which no response is required.
28. This paragraph constitutes a conclusion of law to which no response is required.
DATED: April 1, 2014
es lie Fields, Esquire
I.D. No. 9411
COSTO OULOS, FOSTER & FIELDS
831 Market Street/P.O. Box 222
Lemoyne, Pennsylvania 17043
Phone: 717.761.2121
Fax: 717.761.4031
Email: Lfields@Costopoulos.com
Web: www.Costopoulos.com
ATTORNEY FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I, Leslie M. Fields, Esquire, of Costopoulos, Foster & Fields, do hereby certify on
this 1st day of April, 2014, a true and correct copy of PLAINTIFFS' REPLY TO NEW
MATTER was served upon all counsel of record by:
Hand Delivery
X First Class Mail, Postage Pre-Paid
Certified Mail, Return Receipt Requested
Fax Transmission
Overnight Mail
Electronic Mail
at the following address(es) and/or number(s):
John A. Lucy, Esquire
JOHNSON, DUFFIE, STEWART & WEIDNER
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
717-761-4540
jal@jdsw.com
Attorneys for Defendant, Shyamlata P. Patel
BY: COSTOPOULOS, FOSTER & FIELDS
Leslie M. ields
.IU
PFOIHO
0 4i
20111 f^tY_ 5 PI 2: 07 CERTIFICATE
CUMBERLAND AND co(P REQUISITE TO SERVICE OF A SUBPOENA
PENNSYLVANIA
PURSUANT TO RULE 4009.22
IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA
STEVEN A. RUBY AND ERIN RUBY
vs. TERM:
SHYAMLATA P. PATEL
CASE No: 2013-4487
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 : 05/01/2014
RecordTrak on behalf of
/S/ JOHN LUCY
Attorney for Defendant
RT#: 262073
RECORDS PERTAIN TO: STEVEN A. RUBY
STEVEN A. RUBY AND ERIN RUBY : COURT: Court Of Common Pleas - Cumberland County, Pa
vs. •TERM:
SHYAMLATA P. PATEL : DOCKET: 2013-4487
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS
TO: LESLIE FIELDS, ESQUIRE
COSTOPOULOS, FOSTER & FIELDS
831 MARKET STREET
LEMOYNE, PA 17042
April 18, 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 May 8, 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 8, 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
16
RECORD CUSTODIAN
DR. CHRISTOPHER ROYER
MATERIALS BEING OBTAINED
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 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.************** STEVE A. RUBY,'DOB WNW SS# _,
ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/04- 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.** STEVE A. RUBY, DOB:, SS#1111111111s
, ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/04- PRESENT
17
STEVEN A. RUBY AND ERIN RUBY COURT: Court Of Common Pleas -
Cumberland County, Pa
vs. TERM:
SHYAMLATA P. PATEL DOCKET: 2013-4487
'. NEUROLOGY WELLSPAN
18
HOSPITAL HARRISBURG
(MED)
19
. HOSPITAL HARRISBURG
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 PAILENTS
INFORMATION SHEET. PLEASE BE SURE TO INCLUDE ALL ARCHIVED
RECORDS AND ALL RECORDS LOCATED IN STORAGE. ************PLEASE
SIGN THE ATTACHED CERTIFICATION AND RETURN WTTH THE
RECORDS.************** STEVE A. RUBY, DOBE*, SS#11111Mni, ALL
MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/04- 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.** STEVE A. RUBY, DOBE, SS#,
ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/04- PRESENT
1 . ALL MEDICAL RECORDS 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. STEVE A. RUBY, DOFig/iii, WW1
BALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/04 -
PRESENT
1 . 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.** STEVE A. RUBY, DOBIONIIIIIP SS#
ALL MEDICAL RECORDS IN YOUR POSSESSION FROM 10/6/04 -
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: 262073.16
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A. RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No: 2013-4487
SUBPOENA Tit ' RODUCE DOCUMENT OR THIN S FOR DISCOVER
PURSUANT TO RULE 4009.22
TO: DR. CHRISTOPHER ROYER
(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 King of Prussia PA 19406
You may deliver or mail legible copies of the documents or produce things requested by this subpoea:
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 niay 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: (. iA3 as.aOr
Seal of the Court
Prothonotary
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE #: 262073; TAG 16
LOCATION: DR. CHRISTOPHER ROYER •
RECORDS PERTAIN TO: STEVEN A. RUBY 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
CERIINICATION AND RETURN WITH THE RECORDS.************** STEVE A.
RUBY, DOB X/XX/XX, SS# XXX-XX-XXXX, ALL MEDICAL RECORDS IN YOUR
POSSESSION FROM XX/X/XX- 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.** STEVE A. RUBY, DOB X/XX/XX, SS#
XXX-XX-XXXX, ALL MEDICAL RECORDS IN YOUR POSSESSION FROM XX/X/XX-
PRESENT
RT: 262073.17
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A. RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No:2013-4487
SUByOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: WELT SPAN NEUROLOGY
(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 malting 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 aftc
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: a/
Seal of the Court
RE: STEVEN A. RUBY AND ERIN RUBY vs. SITYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE #: 262073; TAG 17
LOCATION: WELLSPAN NEUROLOGY
RECORDS PERTAIN TO: STEVEN A. RUBY 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 PA IIhNTS 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.************** STEVE A.
RUBY, DOB X/XX/XX, SS# XXX-XX-XXXX, ALL MEDICAL RECORDS IN YOUR
POSSESSION FROM XX/X/XX- 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.** STEVE A. RUBY, DOB X/XX/XX, SS#
XXX-XX-XXXX, ALL MEDICAL RECORDS IN YOUR POSSESSION FROM XX/X/XX-
PRESENT
RT: 262073.18
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A. RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No: 2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: HARRISBURG 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 producing the things sought,
If you fail to produce the documents or things required by this subpoena within twenty (20) days af'te
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
as. atm/
BY THE COURT:
-i t
Prothonotary
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE #: 262073; TAG 18
LOCATION: HARRISBURG HOSPITAL (MED)
RECORDS PERTAIN TO: STEVEN A. RUBY SS #: , DOB:
X . ALL MEDICAL RECORDS INCLUDING INPATIENT, OUTPA I TENT 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. STEVE A. RUBY, DOB X/XX/XX, SS# XXX-XX-XXXX,
ALL MEDICAL RECORDS IN YOUR POSSESSION FROM XX/X/XX- PRESENT
RT: 262073.19
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A. RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No: 2013-4487
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: HARRISBURG 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. 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:
del
Prothonotary
•
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE #: 262073; TAG 19
LOCATION: HARRISBURG HOSPITAL (RAD)
RECORDS PERTAIN TO: STEVEN A. RUBY 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.** STEVE A. RUBY, DOB X/XX/XX, SS#
XXX-XX-XXXX, ALL MEDICAL RECORDS IN YOUR POSSESSION FROM XX/X/XX-
PRESENT
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
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---f
IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA
STEVEN A. RUBY AND ERIN RUBY
vs. TERM:
SHYAMLATA P. PATEL
CASE No: 2013-4487
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 : 09/03/2014
RecordTrak on behalf of
/S/ JOHN LUCY
Attorney for Defendant
RT#: 262073
RECORDS PERTAIN TO: STEVEN A. RUBY
STEVEN A. RUBY AND ERIN RUBY : COURT: Court Of Common Pleas - Cumberland County, Pa
vs. TERM:
SHYAMLATA P. PATEL : DOCKET: 2013-4487
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS
TO: LESLIE FIELDS, ESQUIRE
COSTOPOULOS, FOSTER & FIELDS
831 MARKET ST
LEMOYNE, PA 17043
(717) 761-2121
August 12, 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 September 2, 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 COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING
AND FAX THIS CORRESPONDENCE BY September 2, 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
HOLY SPIRIT HOSPITAL (MED)
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: 262073.21
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A. RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No: 2013-4487
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
651 Allendale Road King of Prussia PA 19406
Yon niay 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 a1te:
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: RecordTralc, JOHN LUCY
Address: 651 Allendale Road King of Prussia PA 19406
Telephone: (8041220-1291
Supreme Court JD#
Attorney for: Defendant
DATE:
Seal of the Court
BY THE COURT:
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE #: 262073; TAG 21
LOCATION: HOLY SPIRIT HOSPITAL (MED)
RECORDS PERTAIN TO: STEVEN A. RUBY SS #: , DOB:
X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/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 PATIENTS INFORMATION SHEET. PLEASE BE SURE
TO INCLUDE ALL ARCHIVED RECORDS AND ALL RECORDS LOCATED IN STORAGE.
************PLEASE SIGN THE ATTACHED CER111'ICATION AND RETURN
WITH THE RECORDS.************
jtj
A t r PREREQUISITE TO SERVICE OF A SUBPOENA
CERTIFICATE
PURSUANT TO RULE 4009.22
IN THE MATTER OF: Court of Common Pleas - Cumberland County, PA
STEVEN A. RUBY AND ERIN RUBY
vs. TERM:
SHYAMLATA P. PATEL
CASE No: 2013-4487
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 : 10/16/2014
RecordTrak on behalf of
/S/ JOHN LUCY
Attorney for Defendant
RT#: 262073
RECORDS PERTAIN TO: STEVEN A. RUBY
STEVEN A. RUBY AND ERIN RUBY : COURT: Court Of Common Pleas - Cumberland County, Pa
vs. : TERM:
SHYAMLATA P. PATEL : DOCKET: 2013-4487
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS
TO: LESLIE FIELDS, ESQUIRE
COSTOPOULOS, FOSTER & FIELDS
831 MARKET ST
LEMOYNE, PA 17043
(717) 761-2121
October 2, 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 October 22, 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 COPIES OF THE RECORDS, PLEASE CONTACT RECORDTRAK FOR PRICING
AND FAX THIS CORRESPONDENCE BY October 22, 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
22
RECORD CUSTODIAN
SILVER CREEK FAMILY HEALTH CENTER
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: 262073.22
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
STEVEN A. RUBY AND ERIN RUBY
V.
SHYAMLATA P. PATEL
File No: 2013-4487
SUBPOENA 70 PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: SILVER CREEK FAMILY HEALTH 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 HO .
Attorney fart'Dc endanr
DATE:
BY THE COURT:
Seal of the Court
RE: STEVEN A. RUBY AND ERIN RUBY vs. SHYAMLATA P. PATEL
CASE NO. 2013-4487
RECORDTRAK FILE #: 262073; TAG 22
LOCATION: SILVER CREEK FAMILY HEALTH CENTER
RECORDS PERTAIN TO: STEVEN A. RUBY SS #: , DOB:
X . ALL MEDICAL RECORDS IN YOUR POSSESSION DATED X/XX/XX 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 PAI hNTS 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.**************